Betty Kendrix - Page 11

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          under regulations prescribed by the Secretary.”  Pursuant to                
          section 170(c), a “charitable contribution” is “a contribution or           
          gift to or for the use of” an organization described in that                
          subsection.                                                                 
               In pertinent part, section 170(f)(8)(A) disallows a                    
          deduction, under section 170(a), “for any contribution of $250 or           
          more unless * * * [substantiated] by a contemporaneous written              
          acknowledgment of the contribution by the donee organization that           
          meets the requirements of subparagraph (B).”  Under section                 
          170(f)(8)(B), the acknowledgment must state the amount of cash              
          and describe (but not value) any property other than cash                   
          contributed, state “whether the donee organization provided any             
          goods and services in consideration, in whole or in part” for the           
          contribution, and provide “[a] description and good faith                   
          estimate of the value of any goods and services” provided by the            
          donee organization “or, if such goods or services consist solely            
          of intangible religious benefits, a statement to that effect.”              
          The term “intangible religious benefit” is defined to mean “any             
          intangible religious benefit which is provided by an organization           
          organized exclusively for religious purposes and which generally            
          is not sold in a commercial transaction outside the donative                
          context.”  Sec. 170(f)(8)(B)(iii).                                          









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Last modified: May 25, 2011