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§ 9.16 LIMITATION ON DEDUCTION FOR EXPENSES DUE TO PLEASUREwill not be permitted a charitable deduction.” 408 Aside from the unexplained insertionof the word “generally,” the implication is that whale-watching and likeundertakings are not sufficiently substantive to constitute the type of charitableservices that give rise to deductible unreimbursed expenses. Similarly, in the othersetting, the IRS took the same position with respect to “study missions.” 409The IRS also stated that an individual who “works on an archaeologicalexcavation sponsored by a charitable organization for several hours each morning,with the rest of the day free for recreation and sightseeing, will not beallowed a deduction even if the taxpayer works very hard during those fewhours.” 410 Although this statement is intended to illustrate the element of duration,411 it appears to indicate that the expense deduction would be available if thevolunteer worked “very hard” on the archaeological dig eight hours a day. Consequently,the IRS view seems to be that passive whale-watching is too passive,whereas full-time hard work at an archaeological evacuation site amounts to sufficientcharitable service to support a charitable deduction for the related unreimbursedexpenses.The IRS further wrote that a “member of a local chapter of a charitable organizationwho travels to New York City and spends an entire day attending theorganization’s regional meeting will not be subject to this provision [denying thecharitable deduction] even if he or she attends the theatre in the evening.” 412Although it is unclear why New York City was singled out for this example, itillustrates that attending meetings for the benefit of a charitable organizationconstitutes substantive services that support the expense deduction.In one case, an individual was denied a charitable deduction for unreimbursedtravel expenses when he traveled as an “official representative” of acharitable organization or when he was merely an “observer.” 413(b) Duration of ServicesAs noted, another element of the “relevant inquiry” in this area is the “duration”of the charitable services provided by the volunteer. 414 The legislative history ofthis law states that Congress was concerned about situations in which the“amount of time spent during the day on activities benefiting the charitableorganization was relatively small compared to the amount of time during theday available for recreation and sightseeing activities.” 415 As the foregoing sectionand the one pertaining to the related area of law 416 indicate, at least eighthours of charitable services per day appear to be necessary to meet the standardand support this aspect of the expense deduction. This is so irrespective ofwhether the services are provided out-of-doors or in meeting rooms.408 IRS Notice 87-23, 1987-1 C.B. 467, 469.409 See § 9.15(c), text accompanied by note 391.410 IRS Notice 87-23, 1987-1 C.B. 467, 469.411 See §§ 9.15(d), 16(b).412 IRS Notice 87-23, 1987-1 C.B. 467, 469.413 Cavalaris v. Commissioner, 72 T.C.M. (CCH) 46, 55 (1996).414 Id. at 54.415 General Explanation at 63.416 See § 9.15(d). 323