Contents

SPECIAL GIFT SITUATIONSUnder the facts of the case that gave rise to this rule, a radio station receivedlodging and transportation rights from hotels and airlines in exchange for theprovision of advertising time. The radio station included the value of the lodgingand transportation in its gross income, and the hotels and airlines included intheir gross incomes the value of the advertising time. The radio station donatedthe lodging and transportation rights to a governmental agency.The IRS concluded that the radio station was entitled to a charitable deductionfor the fair market value of the donated rights. In so doing, the IRS made an analogyto an earlier ruling, in which it upheld the deductibility of a gift to a charitableorganization of a right to receive dance lessons that the donor purchased from adance school. 366 Again, the gift was of property: namely, a purchased contract rightto receive dance lessons.§ 9.15 UNREIMBURSED EXPENSESUnreimbursed expenditures incurred by an individual, in the course of renderingservices that augment or further the program activities of one or more charitableorganizations, may be deductible as charitable contributions. 367 This typeof deduction, which may be thwarted if an element of personal pleasure isinvolved, 368 is in contrast to the rules that preclude a charitable contributiondeduction for a gift of the services themselves 369 or for payments made directlyto individuals by those who are assisting these individuals in their charitableendeavors. 370The range of expenditures that can be deductible in this regard is potentiallysweeping, embracing expenses for the cost of a uniform without general utility,which is required to be worn in performing donated services; transportationexpenses necessarily incurred in performing donated services; and meals andlodging necessarily incurred while away from home in the course of performingdonated services. 371 The rationale for this deduction is that these expenses are notincurred for the benefit of the individual performing the services, but rather forthe benefit of the charitable organization or organizations involved. 372The following unreimbursed expenses, incurred by volunteers, have beenruled to be deductible as charitable contributions:• Expenses incurred by civil defense volunteers in the performance of theirduties (such as traveling expenses and expenses of attending meetings) 373• Expenses incurred by a member of the Civil Air Patrol that are directlyattributable to the performance of services (such as the expenses of acquiring366 Rev. Rul. 68-113, 1968-1 C.B. 80.367 Reg. § 1.170A-1(g).368 See § 9.16.369 See § 9.14.370 See, e.g., Rev. Rul. 55-4, 1955-1 C.B. 291.371 Reg. § 1.170A-1(g). The phrase “while away from home” has the same meaning as in the business expensededuction area (IRC § 162), which means that an individual’s unreimbursed expenses for meals incurred whilerendering services are deductible only if the nature of the travel requires the individual to sleep or rest. See, e.g.,United States v. Correll, 389 U.S. 299 (1967); Saltzman v. Commissioner, 54 T.C. 722 (1970).372 Rev. Rul. 56-508, 1956-2 C.B. 126, modified by Rev. Rul. 84-61, 1984-1 C.B. 39.373 Rev. Rul. 56-509, 1956-2 C.B. 129. 318