John T. and Linda L. Hewitt - Page 6

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          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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