- 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