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substantiate the deduction by obtaining a contemporaneous written
acknowledgment of the contribution from the charitable
organization, including an estimate of the value of any goods or
services that the charitable organization provided to the
taxpayer. Under section 6115, a charitable organization that
receives a quid pro quo payment in excess of $75 must inform the
taxpayer that any charitable contribution deduction is limited to
the difference between the value of any money or property
transferred to the charitable organization and the value of any
goods or services that the taxpayer received from the charitable
organization.
Sections 170(f)(8) and 6115 except certain intangible
religious benefits from the substantiation and disclosure
requirements described above. Sections 170(f)(8) and 6115
provide, inter alia, that if a charitable organization is
organized exclusively for religious purposes and provides solely
an intangible religious benefit to a taxpayer in exchange for a
payment, the charitable organization need not assign a value to
the intangible religious benefit.
b. Petitioners’ Contentions
Petitioners contend that (1) sections 170(f)(8) and 6115
make tuition payments to religious schools deductible to the
extent the payments relate to religious education, (2) the
religious education that Emek and Yeshiva Rav Isacsohn provided
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