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§ 9.15 UNREIMBURSED EXPENSES(d) Duration of ServicesIt has also been held that one element of the “relevant inquiry” in this area is the“duration” of the charitable service provided by the volunteer. 392 The little lawthere is on this point in this setting, and the law that may be extrapolated fromthe related context, 393 suggest that to give rise to deductible expenses, the charitableservices must be carried on for the duration of the day (eight hours). Thus,an individual was allowed to deduct expenses incurred in attending the meetingsof and otherwise providing services for a charitable organization when he“routinely spent a full day” doing so. 394This factor also relates to the matter of pleasure entailed by the activities.The more time there is for recreational and personal undertakings, the less timethere is for the provision of substantive services and the more opportunity forimpermissible pleasure.(e) Excessive ExpendituresUnreimbursed expenditures for items such as meals and lodging, incurred inconnection with charitable activities, must be reasonable to be deductible. 395These outlays, and also those for transportation, must be necessarily incurred. 396Inasmuch as a requirement of reasonableness is inherent in the concept of necessary,397 these expenses for travel, meals, and lodging “must be both reasonable andnecessary.” 398In one case, an individual was active with three charitable organizationsand undertook considerable travel in connection with his volunteer work forthem. The IRS disallowed some of his deductions for unreimbursed expenses, inpart on the ground that they were lavish or extravagant. The IRS asserted that hestayed in “deluxe” hotels; a court, however, allowed the deductions because,although the outlays were not “frugal,” they were for the hotels that hosted theparticular meetings (or similarly priced ones nearby), and thus were “convenient”and saved him additional travel expense. 399 The rental of a hotel suitewas found to be reasonable because the individual stayed one week and used thesuite as a meeting place for officials of one of the charitable organizations. Also,this individual “held relatively prestigious positions in large charitable organizations,such that staying in quality lodgings may have been acceptable practice.”400 The court was of the view, however, that this individual was overlygenerous in his practice of dispensing gratuities and disallowed most of thoseoutlays.392 Cavalaris v. Commissioner, 72 T.C.M (CCH) 46, 54 (1996).393 See § 9.16(b).394 Cavalaris v. Commissioner, 72 T.C.M (CCH) 46, 54 (1996).395 Reg. § 1.170A-1(g).396 Id.397 Boser v. Commissioner, 77 T.C. 1124 (1981).398 Cavalaris v. Commissioner, 72 T.C.M (CCH) 46, 51 (1996).399 Id.400 Id. 321