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GIFTS OF MONEY AND PROPERTYprovided a suggested share price based on the new asset value of the bank. Theprocedure for someone wishing to purchase or sell shares of the corporation wasto contact an officer of the bank or a local stock brokerage firm specializing in theshares. An attempt would be made to match a potential seller with a potentialbuyer; the shares were not frequently sold. The court held that the stock couldnot constitute qualified appreciated stock because the market quotations requirementhad not been satisfied. 50The term qualified appreciated stock does not include any stock of a corporationcontributed by a donor to a private foundation to the extent that the amountof stock contributed (including prior gifts of the stock by the donor) exceeds 10percent (in value) of all of the outstanding stock of the corporation. 51 In makingthis calculation, an individual must take into account all contributions made byany member of his or her family. 52The IRS, from time to time, issues private letter rulings as to whether stockconstitutes qualified appreciated stock. 53§ 4.6 GIFTS OF PROPERTY FOR UNRELATED USEAnother special rule concerning calculation of the charitable deduction potentiallyapplies when a donor makes a contribution of tangible personal propertyto a charitable organization.(a) General RuleThe special rule is as follows: When a charitable gift of tangible personal propertyis made, the amount of the charitable deduction that would otherwise bedetermined must be reduced by the amount of gain that would have been longtermcapital gain if the property contributed had been sold by the donor at itsfair market value, determined at the time of the contribution, when the use bythe donee is unrelated to the donee’s tax-exempt purpose. 54 This rule alsoapplies when the donee is a governmental unit, if the use to which the contributedproperty is put is for a purpose other than an exclusively public purpose. 5550 The court concluded that the market quotations requirement has the same meaning for the purpose of definingthe phrase qualified appreciated stock and in determining when securities are publicly traded so as to exempta donor from the appraisal requirements (see § 21.2, text accompanied by note 80).51 IRC § 170(e)(5)(C)(i).52 IRC § 170(e)(5)(C)(ii). The term member of the family has the same meaning as that referenced in IRC §267(c)(2), which is that the family of an individual “include[s] only his [or her] brothers and sisters (whetherby the whole or half blood), spouse, ancestors, and lineal descendants.” IRC § 267(e)(4).For purposes of applying this 10 percent limitation, the fact that the private foundation subsequently disposedof qualified appreciated securities is irrelevant (the stock contributed is still subject to the limitation thatsecurities contributed from an estate are not attributable to an individual for purposes of computing the limitation(because an income tax charitable contribution deduction was not claimed or allowable, IRC §170(e)(1)(B)(ii)), and, in applying the limitation, securities are valued as of the time of their original contribution(i.e., they are not revalued when subsequent contributions are made). Priv. Ltr. Rul. 200112022.53 E.g., Priv. Ltr. Rul. 9247018.54 IRC § 170(e)(1)(B)(i); Reg. § 1.170A-4(b)(2)(ii).55 Id. 134