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23CHAPTER TWENTY-THREESpecial Events and CorporateSponsorships§ 23.1 IRS Audit Guidelines 618(a) Regulatory History 618(b) Special EmphasisProgram 619(c) Checksheet 619(d) Audit Guidance 621§ 23.2 Special Events 621§ 23.3 Corporate SponsorshipRules 623(a) Background 623(b) Qualified SponsorshipPayments 624As is discussed throughout the book, a payment to a charitable organization is notalways deductible as a charitable gift for federal income tax purposes. 1 Paymentsthat can fall into these categories of questionable transfers are:• A payment when the donor is provided some tangible item of property inexchange for the contribution, so that only a portion of the transaction is acharitable gift• A payment when the donor is provided some benefit, service, or privilegein exchange for the contribution, so that only a portion of the transactionis a charitable gift• A payment when the donor is provided with an item of property, or abenefit, service, or privilege to the extent that none of the payment constitutesa charitable giftYears ago, the IRS launched a Special Emphasis Program to disseminate informationabout the law on these points and to provide audit guidance to its agentsin the field. Two types of fundraising practices have dominated the developmentof the law in this area: special events and donor recognition programs. This bodyof law addresses the question of whether payments to a charitable organizationare, in whole or in part, tax deductible as gifts, as well as the question of whetherthe charitable organization that is the recipient of these payments must pay theunrelated business income tax on them.1 See, e.g., § 3.2. 617