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constitute a significant element of the first and third trips.
Petitioner provided an itinerary for the second trip showing the
activities he undertook while attending the funeral of the
Patriarch. However, petitioner has failed to establish that he
provided any charitable services while on this sojourn. We
conclude that petitioner attended the funeral as an observer. In
sum, we find that section 170(j) prohibits a deduction for the
traveling expenses incurred on petitioner's three trips to Athens
and Istanbul. Compare Seed v. Commissioner, 57 T.C. 265 (1971).
While the gifts petitioner made to the Greek Orthodox Church
on the second trip could be viewed as traveling expenses, they
may also be viewed as independent charitable contributions.
Thus, these expenses must be analyzed separately. Petitioner
claimed a deduction for gifts on the second trip in the amount of
$873. A review of the exhibits reveals that petitioner has only
substantiated $37.30 of this amount. The evidence consists of
two receipts, one for silver polish in the amount of $15.30 and
one for tequila in the amount of $22. Petitioner failed to
explain, and we fail to see, the usefulness of a bottle of
tequila to the Greek Orthodox Church. We conclude that the
tequila was, more likely than not, purchased for personal
consumption or as a nondeductible gift to a specific individual.
Accordingly, petitioner is entitled to a deduction in the amount
of $15.30 for gifts made on the second trip.
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