- 6 -
prescribed by the Secretary." Where the charitable contribution
consists of property other than cash, the value of the
contribution, with exceptions not relevant here, is the fair
market value of the donated property at the time of contribution.
Sec. 1.170A-1(c)(1), Income Tax Regs.
A further applicable statutory provision is section 155 of
the Tax Reform Act of 1984 (Division A of the Deficit Reduction
Act of 1984), Pub. L. 98-369, 98 Stat. 494, 691 (hereinafter
referred to as section 155), which had its origins in proposed
amendments to section 170 set forth in section 154 of the
legislation as passed by the Senate. S. Comm. on Finance,
Deficit Reduction Act of 1984, Statutory Language of Provisions
Approved by the Committee on March 21, 1984, S. Prt. 98-169, vol.
II, at 449-459 (S. Comm. Print 1984); H. Conf. Rept. 98-861, at
993-999 (1984), 1984-3 C.B. (Vol. 2) 1, 247-253. The Senate
provision contained detailed rules regarding substantiation of
contributions of property to charitable organizations.6 Section
155, in its final form, adopted an approach which did not amend
section 170 but provided separate rules for such substantiation.
6 The House version did not contain a comparable provision.
H. Conf. Rept. 98-861, at 993 (1984), 1984-3 C.B. (Vol. 2) 1,
247. Subsec. (j)(5) of the proposed Senate amendment to sec. 170
provided that failure to comply with the appraisal provision
would result in the disallowance of the excess of the value of
the charitable contribution over basis rather than the entire
contribution. S. Comm. on Finance, Deficit Reduction Act of
1984, Statutory Language of Provisions Approved by the Committee
on March 21, 1984, S. Prt. 98-169, vol. II, at 451-452 (S. Comm.
Print 1984).
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