Richard Lewis Field - Page 12

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          charitable, scientific, literary, or educational purposes.  Sec.            
          170(c)(2)(B).  No deduction is allowed under section 170 for a              
          contribution of services.  However, unreimbursed expenditures               
          made incident to the rendition of services to a charitable                  
          organization may constitute a deductible contribution.  Sec.                
          1.170A-1(g), Income Tax Regs.  Allowable deductions include                 
          transportation expenses and reasonable expenses for meals and               
          lodging necessarily incurred while away from home.  Id.                     
               Section 170(j) prohibits a deduction for, inter alia,                  
          unreimbursed traveling expenses incurred incident to the                    
          rendition of charitable services, “unless there is no significant           
          element of personal pleasure, recreation, or vacation in such               
          travel.”  The meaning of a “significant element of personal                 
          pleasure, recreation, or vacation” is far from self-evident.  An            
          inquiry into the legislative history of this provision provides             
          some insight.  The House report states:                                     
               In determining whether travel away from home involves a                
               significant element of personal pleasure, recreation,                  
               or vacation, the fact that a taxpayer enjoys providing                 
               services to the charitable organization will not lead                  
               to denial of the deduction. * * * A taxpayer who only                  
               has nominal duties relating to the performance of                      
               services for the charity, or who for significant                       
               portions of the trip is not required to render                         
               services, is not allowed any deduction for travel                      
               costs.  [H. Rept. 99-426 (1985); 1986-3 C.B. (Vol. 2)                  
               129].                                                                  









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