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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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