Richard Lewis Field - Page 13

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          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.                 







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