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GIFTS OF MONEY AND PROPERTYEXAMPLE 4.8This example is based on the facts of Example 4.7. Instead of the educational uses made of thepainting, however, the educational institution decided to promptly sell the painting and use theproceeds of sale for educational purposes. This use of the property was an unrelated use and X’scharitable deduction computed under this rule was $25,000 ($50,000 reduced by the longtermcapital gain element of $25,000). This is the case even though the proceeds of the salewere put to a related use.If furnishings contributed to a charitable organization are used by it in itsoffices and buildings in the course of carrying out its functions, the use of theproperty is not an unrelated use. If a set or collection of items of tangible personalproperty is contributed to a charitable organization or governmental unit,the use of the set or collection is not an unrelated use if the donee sells or otherwisedisposes of only an insubstantial portion of the set or collection. The use bya trust of tangible personal property contributed to it for the benefit of a charitableorganization is an unrelated use if the use by the trust is one that would havebeen unrelated if used directly by the charitable organization. 61A donor who makes a charitable contribution of tangible personal propertyto or for the use of a charitable organization or governmental unit may treat theproperty as not being put to an unrelated use by the donee if:• the donor establishes that the property is not in fact put to an unrelateduse by the donee, 62 or• at the time of the contribution or at the time the contribution is treated asmade, it is reasonable to anticipate that the property will not be put to anunrelated use by the donee. 63In the case of a contribution of tangible personal property to or for the use of amuseum, if the object donated is of a general type normally retained by themuseum or other museums for museum purposes, it is considered reasonablefor the donor to anticipate, unless the donor has actual knowledge to the contrary,that the object will not be put to an unrelated use by the donee, whether ornot the object is later sold or exchanged by the donee. 64§ 4.7 VARIATIONS IN APPLYING PROPERTY RULESThe rules contained in this section and the previous sections may be illustratedby Examples 4.9, 4.10, and 4.11.61 Id. The last of these rules is of particular importance in the context of planned giving, where property contributedis often given to a trust, such as a charitable remainder trust (see in particular, Chapter 12).62 Reg. § 1.170A-4(b)(3)(ii)(a).63 Reg. § 1.170A-4(b)(3)(ii)(b).64 Id. In general, see “Transcript of the Spring ABA EO Committee Meeting—Panel Two: Gifts of Tangible PersonalProperty: Tax Issues from the Standpoint of the Donor”, 8 Exempt Org. Tax Rev. (no. 1) 72 (1993). 136