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set in the note itself), the 1982 deduction should be discounted
no more than $300.
To the contrary, respondent contends that the Kanters are
not entitled to the claimed charitable deduction for 1982 on
alternative grounds because (1) there was no endorsement of the
Holding Co. promissory note by Kanter to JUF, or (2) the Kanters
failed to establish the note's fair market value on the date of
its purported contribution to JUF in late 1982. On brief,
respondent concedes that the Kanters are entitled to a charitable
contribution deduction for 1983 for the $15,000 because Kanter
paid that amount to JUF in 1983, subject to the adjusted gross
income limitations of section 170(b) for 1983.
Ordinarily, a charitable contribution is made at the time
delivery is effected. If a taxpayer unconditionally delivers or
mails a properly endorsed stock certificate to a charitable donee
or the donee's agent, the gift is completed on the date of
delivery. See sec. 1.170A-1(b), Income Tax Regs. Respondent
argues that, like a stock certificate, a promissory note is
delivered to a donee only after it has been properly endorsed and
unconditionally delivered to the donee. Here Kanter failed to
establish that he endorsed the Holding Co. promissory note over
to JUF. As evidence that he contributed the note to JUF, Kanter
introduced a copy of only the front page of the note; a copy of
his pledge card; a copy of a Holding Co. letter reciting delivery
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