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RECEIPT, RECORDKEEPING, AND REPORTING REQUIREMENTSdonee provides any goods or services in consideration, in whole or inpart, for the unreimbursed expenditures; and (3) the information summarizedin the third and fourth of the items that must be reflected in thewritten acknowledgment. 58The substantiation rules do not apply to a transfer of property to a charitableremainder trust or a charitable lead trust. 59 They do, however, apply withrespect to transfers by means of pooled income funds. 60 The reason for this distinctionis grounded in the fact that the grantor of a remainder trust or lead trustis not required to designate a specific organization as the charitable beneficiaryat the time property is transferred to the trust, so in these instances there is nodesignated charity available to provide a contemporaneous written acknowledgmentto the donor. Also, even when a specific beneficiary is designated, theidentification of the charity can be revocable. By contrast, a pooled income fundmust be created and maintained by the charitable organization to which theremainder interests are contributed.If a partnership or S corporation makes a charitable contribution of $250 ormore, the partnership or corporation is treated as the taxpayer for gift substantiationpurposes. 61 Therefore, the partnership or corporation must substantiate thecontribution with a contemporaneous written acknowledgment from the doneecharity before reporting the contribution on its information return or income taxreturn for the appropriate year, and must maintain the contemporaneous writtenacknowledgment in its records. A partner of a partnership or a shareholder of anS corporation is not required to obtain any additional substantiation for his orher share of the partnership’s or S corporation’s charitable contribution.If a person’s payment to a charitable organization is matched, in whole or inpart, by another payor, and the person received goods or services in considerationfor the payment and some or all of the matched payment, the goods or servicesare treated as provided in consideration for the person’s payment and notin consideration for the matching payment. 62The required substantiation may be provided by a properly authorizedagent of the charitable donee. 63 For example, when the contribution is of a usedvehicle, a for-profit fundraising company or other entity licensed to sell vehicles58 Reg. § 1.170A-13(f)(10).59 Reg. § 1.170A-13(f)(13). Charitable remainder trusts are the subject of Chapter 12 and charitable lead trustsare the subject of Chapter 16.60 Pooled income funds are the subject of Chapter 13.61 Reg. § 1.170A-13(f)(15). If a person purchases an annuity from a charitable organization and claims a charitablecontribution deduction of $250 or more for the excess of the amount paid over the value of the annuity,the contemporaneous written acknowledgment must state whether any goods or services in addition to theannuity were provided to the person. Reg. § 1.170A-13(f)(16). The contemporaneous written acknowledgmentneed not include a good faith estimate of the value of the annuity. Id.62 Reg. § 1.170A-13(f)(17). An idea for simplified compliance by donors and donees with the charitable giftsubstantiation rules is the subject of discussion in the charitable community. See, e.g., 69 Tax Notes 793(Nov. 6, 1995). The thought advanced is that the contributor has a rubber stamp made, by which the followingis printed on the back of the contribution check: “The negotiation of this check constitutes an acknowledgmentthat the amount thereof was received by the payee as a charitable contribution and that no goodsor services were provided in consideration thereof.” The Department of the Treasury has never addressedthe efficacy of this approach.63 See § 10.1(c). 592