Charles T. McCord, Jr. and Mary S. McCord, Donors - Page 100

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          interest charitable gifts are subject to strict guidelines which            
          provide assurance that the charitable deductions to be allowed              
          reflect the approximate amount to be received by charity.  See              
          sec. 25.2522(c)-3(d)(2)(iv), Gift Tax Regs.                                 
               In addition to the above statutorily qualified forms of                
          deductible partial interests transferred to charity, section                
          170(f)(3)(B) sets forth a number of other types of partial                  
          interest gifts with respect to which charitable deductions are              
          allowable.  Under section 170(f)(3)(B), charitable deductions are           
          allowed for gifts not in trust of remainder interests in a                  
          personal residence or farm (sec. 170(f)(3)(B)(i)), gifts to                 
          charity not in trust of an “undivided portion” of a transferor’s            
          entire interest in property (sec. 170(f)(3)(B)(ii)), and                    
          qualified conservation contributions (sec. 170(f)(3)(B)(iii)).              
          With regard to charitable gifts of an undivided portion of a                
          transferor’s entire interest in property, section 25.2522(c)-               
          3(c)(2)(i), Gift Tax Regs., provides, in part, as follows:                  

               An undivided portion of a donor’s entire interest in                   
               property must consist of a fraction or percentage of                   
               each and every substantial interest or right owned by                  
               the donor in such property * * *.2  * * *                              



               2  Parallel provisions for income and estate tax purposes              
          with regard to deductions relating to charitable gifts of an                
          undivided portion of a taxpayer’s entire interest in property are           
          set forth in sec. 1.170A-7(b)(1)(i), Income Tax Regs., and sec.             
          20.2055-2(e)(2)(i), Estate Tax Regs.                                        





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