184 
‘‘(3) QUALIFIED ORGANIZATION.—For purposes 
of paragraph (1), the term ‘qualified organization’ 
means an organization which— 
‘‘(A) is described in clause (v) or (vi) of 
subsection (b)(1)(A), or 
‘‘(B) is described in section 253(c)(3) 
and— 
‘‘(i) meets the requirements of section 
102(a)(2), or 
‘‘(ii) meets the requirements of sec-
tion 102(a)(3) and is controlled by an or-
ganization described in subparagraph (A) 
or in clause (i) of this subparagraph. 
‘‘(4) CONSERVATION PURPOSE DEFINED.— 
‘‘(A) IN GENERAL.—For purposes of this 
subsection, the term ‘conservation purpose’ 
means— 
‘‘(i) the preservation of land areas for 
outdoor recreation by, or the education of, 
the general public, 
‘‘(ii) the protection of a relatively nat-
ural habitat of fish, wildlife, or plants, or 
similar ecosystem,
185 
‘‘(iii) the preservation of open space 
(including farmland and forest land) where 
such preservation is— 
‘‘(I) for the scenic enjoyment of 
the general public, or 
‘‘(II) pursuant to a clearly delin-
eated Federal, State, or local govern-
mental conservation policy, and will 
yield a significant public benefit, or 
‘‘(iv) the preservation of an histori-
cally important land area or a certified his-
toric structure. 
‘‘(B) CERTIFIED HISTORIC STRUCTURE.— 
For purposes of subparagraph (A)(iv), the term 
‘certified historic structure’ means any building, 
structure, or land area which— 
‘‘(i) is listed in the National Register, 
or 
‘‘(ii) is located in a registered historic 
district and is certified by the Secretary of 
the Interior to the Secretary as being of 
historic significance to the district. 
A building, structure, or land area satisfies the 
preceding sentence if it satisfies such sentence 
either at the time of the transfer or on the due
186 
date (including extensions) for filing the trans-
feror’s return under this chapter for the taxable 
year in which the transfer is made. 
‘‘(5) EXCLUSIVELY
FOR
CONSERVATION
PUR-
POSES.—For purposes of this subsection— 
‘‘(A) CONSERVATION
PURPOSE
MUST
BE 
PROTECTED.—A contribution shall not be treat-
ed as exclusively for conservation purposes un-
less the conservation purpose is protected in 
perpetuity. 
‘‘(B) NO SURFACE MINING PERMITTED.— 
‘‘(i) IN
GENERAL.—Except as pro-
vided in clause (ii), in the case of a con-
tribution of any interest where there is a 
retention of a qualified mineral interest, 
subparagraph (A) shall not be treated as 
met if at any time there may be extraction 
or removal of minerals by any surface min-
ing method. 
‘‘(ii) SPECIAL RULE.—With respect to 
any contribution of property in which the 
ownership of the surface estate and min-
eral interests were separated before June 
13, 1976, and remain so separated, sub-
paragraph (A) shall be treated as met if
187 
the probability of surface mining occurring 
on such property is so remote as to be neg-
ligible. 
‘‘(6) QUALIFIED
MINERAL
INTEREST.—For 
purposes of this subsection, the term ‘qualified min-
eral interest’ means— 
‘‘(A) subsurface oil, gas, or other minerals, 
and 
‘‘(B) the right to access to such minerals. 
‘‘(f) DENIAL OF DEDUCTION FOR CERTAIN TRAVEL 
EXPENSES.—No deduction shall be allowed under section 
211 for traveling expenses (including amounts expended 
for meals and lodging) while away from home, whether 
paid directly or by reimbursement, unless there is no sig-
nificant element of personal pleasure, recreation, or vaca-
tion in such travel. 
‘‘(g) TREATMENT OF CERTAIN AMOUNTS PAID TO OR 
FOR THE BENEFIT OF INSTITUTIONS OF HIGHER EDU-
CATION.—For purposes of section 9, if as the result of 
a contribution to or for the benefit of an educational orga-
nization— 
‘‘(1) 
which 
is 
described 
in 
subsection 
(b)(1)(A)(ii), and 
‘‘(2) which is an institution of higher education 
(as defined in section 3304(f))
188 
the taxpayer receives (directly or indirectly) as a result 
of paying such amount the right to purchase tickets for 
seating at an athletic event in an athletic stadium of such 
institution, 80 percent of such contribution shall be treat-
ed as a charitable contribution (but only if such amount 
would be allowable as a deduction but for the fact that 
the taxpayer received the right to purchase tickets). If any 
portion of a payment is for the purchase of such tickets, 
such portion and the remaining portion (if any) of such 
payment shall be treated as separate amounts for purposes 
of this subsection. 
‘‘Subchapter F—Special Business Activities 
‘‘Sec. 111. Rules for rental of real estate. 
‘‘SEC. 111. RULES FOR RENTAL OF REAL ESTATE. 
‘‘(a) IN GENERAL.—Except as provided in subsection 
(b)— 
‘‘(1) the activity of rental of real estate is a 
business activity to which the Simplified USA Tax 
for businesses under chapter 2 applies, 
‘‘(2) a taxpayer shall not be entitled to any de-
ductions under this chapter with respect to rental 
property, and 
‘‘(3) a taxpayer shall recognize gross income 
only with respect to distributions from the rental ac-
tivity.