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§ 6.14 GIFTS BY PARTNERSHIPSTo satisfy this rule, contributions of property need not be segregated by yearand there is no requirement that the donees be identified at the time the resolutionis adopted. 61This rule applies only to regular, or C, corporations; deductions under thisrule are not available to S corporations, which are treated the same as partnershipsfor tax purposes. 62 (Each shareholder of an S corporation takes intoaccount the shareholder’s pro rata share of the corporation’s items of income,loss, deduction, or credit.) 63 Rather, an S corporation must report the charitablecontribution on its tax return for the year in which the contribution was actuallymade. 64 This is because an S corporation generally computes its taxable incomein the same manner as an individual. 65 Certain deductions are not allowable toan S corporation; this includes the charitable contribution deduction. 66§ 6.14 GIFTS BY PARTNERSHIPSThe taxable income of a partnership generally is computed in the same manneras for individuals; however, the charitable contribution deduction is not allowedto the partnership. 67 Rather, each partner takes into account separately the partner’sdistributive share of the partnership’s charitable contributions. 68A partner’s distributive share of charitable contributions made by a partnershipduring a tax year of the partnership is allowed as a charitable deduction onthe partner’s tax return for the partner’s tax year within which the tax year ofthe partnership ends. 69 The aggregate of the partner’s share of partnership contributionsand the partner’s own (directly made) contributions are subject to thevarious percentage limitations on annual deductibility. 70Moreover, when a partnership makes a charitable contribution of property,the basis of each partner’s interest in the partnership is decreased (but not belowzero) by the amount of the partner’s share of the partnership’s basis in the propertycontributed. 71The adjusted basis of a partner’s interest in a partnership must be increased bythe sum of the partner’s distributive share for the tax year and prior tax years ofthe taxable income of the partnership, the income of the partnership that is exemptfrom tax, and the excess of the deductions for depletion over the basis of the propertysubject to depletion. 72 The adjusted basis of a partner’s interest in a partnershipmust be decreased (but not below zero) by distributions by the partnership,61 Priv. Ltr. Rul. 7802001. This rule was created because corporations intending to make the maximum charitablecontribution allowable as a deduction experienced difficulty in determining, before the end of the tax year,what would be their net income (S. Rep. No. 831, 81st Cong., 1st Sess. (Vol. 3) 3−4 (1949)).62 See § 6.14.63 IRC § 1366(a)(1)(A).64 Rev. Rul. 2000-43, 2000-2 C.B. 333.65 IRC § 1363(b). The election provided by IRC § 170(a)(2) is not available to an individual.66 IRC § 703(a)(2)(C).67 IRC § 703(a)(2)(C).68 IRC § 702(a)(4); Reg. §§ 1.702-1(a)(4), 1.703-1(a)(2)(iv).69 Reg. § 1.170A-1(h)(7).70 See Chapter 7.71 Rev. Rul. 96-11, 1996-1 C.B. 140.72 IRC § 705(a)(1). 183