John C. and Tate M. Todd - Page 10




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                    (B) Qualified appreciated stock.--* * *                           
                    for purposes of this paragraph, the term                          
                    “qualified appreciated stock” means any stock                     
                    of a corporation--                                                
                           (i) for which (as of the date of the                       
                           contribution) market quotations are readily                
                           available on an established securities                     
                           market, and                                                
                           (ii) which is capital gain property (as                    
                           defined in subsection (b)(1)(C)(iv)).                      
               B.  Regulations                                                        
               Section 1.170A-13, Income Tax Regs., sets forth record                 
          keeping and return requirements for deductions for charitable               
          contributions.  Paragraph (c) thereof applies to charitable                 
          contributions made after December 31, 1984, by, among others, an            
          individual of an item of property “other than money and publicly            
          traded securities to which � 1.170A-13(c)(7)(xi)(B) does not                
          apply” if the amount claimed or reported as a deduction with                
          respect to the property exceeds $5,000.  Paragraph (c) further              
          provides:  “No deduction under section 170 shall be allowed with            
          respect to a charitable contribution to which this paragraph                
          applies unless the substantiation requirements described in                 
          paragraph (c)(2) of this section are met.”  In pertinent part,              
          section 1.170A-13(c)(2)(i), Income Tax Regs., provides:                     
                    (2) Substantiation requirements.  (i) In general.                 
               * * * a donor who claims or reports a deduction with                   
               respect to a charitable contribution to which this                     
               paragraph (c) applies must comply with the following                   
               three requirements:                                                    







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