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SPECIAL GIFT SITUATIONSIn one case, an individual stayed at resort hotels to attend meetings of charitableorganizations. Although golf and tennis tournaments were held, he “routinelyspent a full day attending meetings or otherwise providing services while attendingconferences,” which “preclud[ed] participation in the recreational activities.” 417The deduction for his unreimbursed expenses was upheld.As the previous section also indicates, there cannot be an allocation of servicesin support of an expense deduction for a portion of unreimbursed expenses.The legislative history of this law states that there is no deduction in a situationinvolving an individual “who for significant portions of the trip is not requiredto render services.” 418 For example, at least according to the IRS’s view of thelaw, an individual cannot provide substantive services for the benefit of a charitableorganization for four hours a day and properly claim a charitable deductionfor one-half of the unreimbursed expenses incurred for travel, meals, andlodging.(c) Element of PleasureAs noted, no charitable contribution deduction is available for expenses incurredfor traveling, meals, and lodging while away from home, whether paid directlyor by reimbursement, “unless there is no significant element of personal pleasure,recreation, or vacation” involved. 419 This requires identification and quantificationof a pleasure element. Inexplicably, in interpreting this rule, a court wrote thatthe “relevant inquiry is the extent [see above] and duration [see above] of thecharitable services provided by the taxpayer, and not some quantum measure ofpleasure derived by the taxpayer.” 420 Given the language of the statute, an assessmentof a “quantum measure of pleasure” derived by a service provider in thissetting seems unavoidable.The only conceivable explanation for this dismissal of the pleasure elementmust be found in an analysis of the context in which it was written. In the case,the court allowed the claimed deduction for expenses for travel to a resort location,where golf and tennis activities were featured, because the individual serviceprovider served on the charitable organization’s executive committee andwas forced to participate in meetings all day, and thus could not partake ofsocial activities except in the evening. This approach correlates with the IRS’sview that the expense deduction is available when the service provider participatesin substantive meetings all day for the benefit of a charitable organization,notwithstanding pleasurable undertakings (such as the theater) after hours(such as in the evening). 421 The import of this approach seems to be that the elementof pleasure, recreation, or vacation does not become significant when the dayalso includes at least eight hours of substantive activities engaged in for theadvancement of charitable purposes. (This exercise nonetheless cannot ignore a417 Cavalaris v. Commissioner, 72 T.C.M. (CCH) 46, 54 (1996).418 H. Rep. No. 99-426, 99th Cong., 1st Sess. 129 (1985).419 IRC § 170(j).420 Cavalaris v. Commissioner, 72 T.C.M. (CCH) 46, 54 (1996).421 See § 9.16(a), text accompanied by note 412. 324