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SPECIAL GIFT SITUATIONS(f) Element of PleasureAs noted, the rationale for the deductibility of these expenses is that they areincurred for the benefit of the charitable organization involved, not for the benefit ofthe participating individual. 401 Thus, the more the individual derives pleasurefrom his or her undertakings for a charitable organization, the less likely it is thatthe related unreimbursed expenses will be deductible. In one case, the court concludedthat an individual who traveled to attend folk dance festivals could notdeduct the expenses as a charitable contribution, even though he acquired knowledgethat he used in rendering services to a charitable organization, because hederived “substantial personal pleasure” from participation in the festivals. 402This principle is more fully developed in the body of law summarized in thenext section.§ 9.16 LIMITATION ON DEDUCTION FOR EXPENSESDUE TO PLEASUREThere is no charitable contribution deduction for expenses incurred for traveling,meals, and lodging while away from home, whether paid directly or by reimbursement,“unless there is no significant element of personal pleasure, recreation,or vacation” involved. 403 This rule also applies when the expenses are paid“by some indirect means such as by contribution to the charitable organizationthat pays for the taxpayer’s travel [and other] expenses.” 404This body of law focuses on three of the six elements summarized in the previoussection: the substance of the services, the duration of the services, and theextent of any pleasure derived by the individual providing the services.(a) Substance of ServicesAs noted, one element of the “relevant inquiry” in this area is the “extent”—orsubstance—of the charitable services provided by the volunteer. 405 The legislativehistory of this law states that the individual must be “on duty in a genuine andsubstantial sense throughout the trip” to be entitled to the deduction for unreimbursedexpenses; the deduction is not available when the individual “only hasnominal duties relating to the performance of services for the charity.” 406 The historyalso indicates that Congress was concerned about situations in which the“value of the services performed appeared to be minimal compared to theamount deducted.” 407For example, the IRS states that an individual “who sails from one CaribbeanIsland to another and spends eight hours a day counting whales and other formsof marine life as part of a project sponsored by a charitable organization generally401 Rev. Rul. 56-508, 1956-2 C.B. 126.402 Saltzman v. Commissioner, 54 T.C. 722 (1970).403 IRC § 170(j).404 IRS Notice 87-23, 1987-1 C.B. 467, 469.405 Cavalaris v. Commissioner, 72 T.C.M (CCH) 46, 54 (1996). See § 9.15(c).406 H. Rep. No. 99-426, 99th Cong., 1st Sess. 129 (1985). See also General Explanation of the Tax Reform Act of1986 (JCS-10-87), 99th Cong., 2d Sess. (1986) [hereinafter General Explanation], at 73.407 General Explanation at 63. 322