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§ 9.17 AUTOMOBILE EXPENSES“quantum measure of pleasure,” but rather should lead to a conclusion that thepleasure component is insignificant.)In another case, an individual incurred expenses in connection with participationin a safari, in which he collected animals and donated them to a museum.The court allowed the deduction, emphasizing the factor of the individual’sintent: that is, whether he undertook the trip primarily for furtherance of charitablepurposes or for his “personal pleasure, welfare or economic benefit or entertainment.”422 Yet, in a nearly identical case, the deduction was not allowed. 423 Aseries of cases holds that the expenses of participating in “People-to-People”tours are not deductible, because the individual travelers are the primary beneficiariesof the payments. 424Another aspect of this component of the analysis is whether the individualenjoys providing the services to the charitable organization. Presumably, becausethese individuals are serving as volunteers, this type of enjoyment is alwayspresent, although there may be degrees of it. The legislative history of this lawstates that, in determining whether travel away from home involves a significantelement of personal pleasure, recreation, or vacation, the “fact that a taxpayerenjoys providing services to the charitable organization will not lead to denial ofthe deduction.” 425 The example is given of a troop leader for a tax-exempt youthgroup who takes children belonging to the group on a camping trip; the leader’stravel expenses in this connection are deductible if he or she is “on duty in a genuineand substantial sense throughout the trip, even if he or she enjoys the tripor enjoys supervising children.” 426§ 9.17 AUTOMOBILE EXPENSESA standard mileage rate can be used, rather than itemization of expenses, in calculatingthe charitable deduction for use of a passenger automobile. That rate is14 cents per mile. 427Rather than deduct automobile expenses, an individual may be reimbursed,by the charitable organization involved, for the expenses incurred. Generally,one who serves as a volunteer for and who provides services to a charitable organization,and is reimbursed by the organization for the expenses of providing theservices, does not receive gross income as a result of the reimbursement. 428 If,however, this type of reimbursement exceeds the amount of the expenses, theexcess amount constitutes gross income. 429 There are some relatively narrowexceptions to these rules, such as reimbursements made to an individual whofunctioned as a volunteer under a retired senior volunteers program governed422 Jersig v. Commissioner, 69-1 U.S.T.C. 9311 (W.D. Tex. 1968) (jury verdict).423 LaGarde v. Commissioner, 76-1 U.S.T.C. 9248 (N.D. Ala. 1975) (jury verdict).424 Sheffels v. United States, 264 F. Supp. 85 (E.D. Wash. 1967), aff’d, 405 F.2d 924 (9th Cir. 1969); Seed v. Commissioner,57 T.C. 265 (1971); MacMichael v. Commissioner, 45 T.C.M. (CCH) 271 (1982).425 H. Rep. No. 99-426, 99th Cong., 1st Sess. 129 (1985).426 Id.427 IRC § 170(i); Rev. Proc. 2003-76, 2003-43 I.R.B. 924, § 7.01. In response to a request for an increase in thismileage reimbursement rate, because of rising gasoline prices, the IRS observed that it cannot change the rate,which is fixed by statute. INFO 2000-0049.428 See, e.g., Rev. Rul. 80-99, 1980-1 C.B. 10 (concerning reimbursements made in a nonemployment context).429 See, e.g., Rev. Rul. 67-30, 1967-1 C.B. 9 (involving a per diem allowance for a volunteer’s travel expenses). 325