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SPECIAL GIFT SITUATIONS(b) Inherent Nature of ServicesIn general, anyone can serve as a volunteer for a charitable organization and beentitled to a charitable contribution deduction for unreimbursed expenses incurred.In other words, the individual who is a volunteer incurring expenses does not haveto be a professional or other expert in a field to serve a charity that is functioning inthat field. Thus, an individual may be a trustee, director, and/or officer of acharitable organization and incur deductible unreimbursed expenses in thatcapacity. 383 Likewise, an individual serving as a lay member of a church mayincur deductible unreimbursed expenses. 384At the same time, the fact that an individual is a professional or other expertin a field does not, in and of itself, preclude deductibility of unreimbursedexpenses. This factor may, however, increase the likelihood that pleasure, undueor otherwise, is being derived from the experience. 385(c) Substance of ServicesIt has been held that one element of the “relevant inquiry” in this area is the“extent” of the charitable services provided by the volunteer. 386 The term substanceprobably is preferable to the term extent. This subjective factor looks to theinherent value to the charitable organization of the services provided. Thisaspect of the matter is more fully developed in the context of the rules concerningpermissible and impermissible pleasure. 387Nonetheless, as an illustration, it has been held that expenses incurred by alay member of a church in attending a church convention as a delegate may bedeductible as a charitable gift. 388 Similarly, expenses incurred by a member of theAmerican Legion who is appointed as a delegate to and attends an AmericanLegion convention may be deductible. 389 In limiting the reach of this aspect ofdeductibility, the IRS makes much of the word delegate, stating that the term “isused in its general meaning of one appointed and sent by another, with authorityto transact business as his [or her] representative.” 390 In other words, the IRSis, in this setting, equating a delegate with an agent. This position enabled the IRSto rule that expenses were not deductible when incurred by an individual inconnection with a “study mission,” when the charity directly served did not conductthe mission, the travel arrangements were made by the individual, and the“itinerary also covered other points of interest that are ordinarily a part of touristsight-seeing schedules.” 391383 See, e.g., Cavalaris v. Commissioner, 72 T.C.M. (CCH) 46 (1996).384 Rev. Rul. 58-240, 1958-1 C.B. 141.385 See § 9.15(c) and (f).386 Cavalaris v. Commissioner, 72 T.C.M. (CCH) 46, 54 (1996).387 See § 9.16.388 Rev. Rul. 58-240, 1958-1 C.B. 141.389 Id.390 Rev. Rul. 71-135, 1971-1 C.B. 94, clarifying Rev. Rul. 58-240, 1958-1 C.B. 141.391 Rev. Rul. 71-135, 1971-1 C.B. 94. 320