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reasonableness of a tip as within the ambit of "experience with
the mainsprings of human conduct". See Commissioner v.
Duberstein, 363 U.S. 278, 289 (1960). We conclude that the
amount petitioner deducted as tips was in excess of a reasonable
amount, and, accordingly, allow $15 per day for such expenses on
each of these four trips.
We next consider whether any of the expenses claimed by
petitioner constitute nondeductible personal or living expenses
pursuant to section 262. Petitioner claimed $161.60 as a
deduction for expenses incurred for gratuities and taxes relating
to the purchase of a 4-day spa plan while on the 11-day Fort
Lauderdale/Miami Beach, Florida, trip (paragraph 10 of the
stipulation of facts). The actual cost of the spa plan was not
deducted. This expenditure was personal and unrelated to
petitioner's performance of charitable services.
On a trip to Atlanta, Georgia (paragraph 15 of the
stipulation of facts), petitioner deducted expenditures for
gasoline. Petitioner's receipts show that he filled the gas tank
before he left his home in Charlotte, North Carolina, and again
when he returned. The second tank of gas was used for
petitioner's personal affairs at home in Charlotte rather than
the trip to Atlanta. Accordingly, we sustain respondent's
disallowance of $15 of the amount claimed for gasoline on this
trip.
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