- 27 -
did not enjoy a "significant element of personal pleasure,
recreation, or vacation" within the meaning of the statute. The
exhibits often contain itineraries detailing the activities
scheduled at a particular conference. These itineraries
corroborate petitioner's testimony and, together, establish that
petitioner routinely spent a full day attending meetings or
otherwise providing services while attending conferences. The
Virginia Beach, Virginia, trip provides a good example. A letter
describing the activities scheduled during this AHEPA conference
indicated that golf and tennis tournaments were scheduled.
However, petitioner served on the national executive committee.
The letter shows that committee meetings lasted all day,
precluding participation in the recreational activities.
Accordingly, we conclude that section 170(j) does not prohibit
petitioner from deducting expenses related to his domestic travel
or his travel to Nassau, Bahamas.
We reach a different conclusion with regard to petitioner's
travel to Athens and Istanbul. Petitioner has provided no
evidence to establish the specific activities he undertook on
either the first or third trip. Regarding the third trip
petitioner asserts that he was an official representative of the
church, however, this in and of itself is not enough to satisfy
section 170(j). Therefore, we are unable to conclude that
elements of personal pleasure, recreation, or vacation did not
Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 NextLast modified: May 25, 2011