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charitable contributions in connection with fund-raising events
involving quid pro quo transactions. To enhance taxpayer
compliance in this area, Congress imposed (a) a new
substantiation requirement under section 170(f)(8),9 and (b) a
8(...continued)
that engage in such fundraising practices often do not
inform their donors that all or a portion of the amount
paid by the donor may not be deductible as a charitable
contribution.
9 Sec. 170(f)(8) provides in pertinent part:
(A) General rule.--No deduction shall be allowed
under subsection (a) for any contribution of $250 or
more unless the taxpayer substantiates the contribution
by a contemporaneous written acknowledgment of the
contribution by the donee organization that meets the
requirements of subparagraph (B).
(B) Content of acknowledgment.--An acknowledgment
meets the requirements of this subparagraph if it
includes the following information:
(i) The amount of cash and a description
(but not value) of any property other than
cash contributed.
(ii) Whether the donee organization
provided any goods or services in
consideration, in whole or in part, for any
property described in clause (i).
(iii) A description and good faith
estimate of the value of any goods or
services referred to in clause (ii) or, if
such goods or services consist solely of
intangible religious benefits, a statement to
that effect.
For purposes of this subparagraph, the term “intangible
religious benefit” means any intangible religious
benefit which is provided by an organization organized
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