- 12 - The example makes clear that the relevant inquiry is the extent and duration of the charitable services provided by the taxpayer, and not some quantum measure of pleasure derived by the taxpayer. Petitioner traveled to England and Wales with the Chorus and deducted his travel expenses as charitable contributions on Schedule A. Respondent contends that petitioner’s trip expenses are not deductible because the trip involved elements of personal pleasure, recreation, or vacation. The record contains an itinerary of petitioner’s trip. An examination of the itinerary reveals that approximately 25 hours of rehearsal and performance time were required. The itinerary also reveals that each day provided opportunities for scheduled or independent sightseeing trips. There were scheduled sightseeing trips on 4 days of the 8-day trip. On 2 of the remaining days, opportunities for independent sightseeing were provided. The blocks of time set aside for sightseeing, either scheduled or independent, totaled approximately 37 hours. Petitioner testified that he did not take advantage of the independent sightseeing opportunities. “You can be sure at my age I was either reading, sleeping, or resting from jet lag during those times and not sightseeing.” It is well established that the Court is not required to accept petitioner’s self- serving testimony in the absence of corroborating evidence.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011