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§ 6.15 GIFTS BY MEANS OF THE INTERNETappreciated property without recognition of the appreciation. By contrast,reducing the partners’ bases in their partnership interests by the fair marketvalue of the contributed property would subsequently cause the partners to recognizegain (or a reduced loss), such as on a disposition of their partnershipinterests, attributable to the unrecognized appreciation in this contributed propertyat the time of the contribution.In the example, under the partnership agreement, partnership items are allocatedequally between A and B. Accordingly, the basis of A’s and B’s interests inthe partnership is reduced by $30,000 each. 78§ 6.15 GIFTS BY MEANS OF THE INTERNETOne of the many issues that has arisen out of the utilization of the Internet as amedium to obtain charitable contributions is the tax consequences of the use offor-profit entities by charitable organizations to collect the payments. These entitiesmay deduct a donation service fee and remit the balance to the charityinvolved.If the gift is considered made to the for-profit organization, the charitablecontribution deduction may be defeated. 79 Otherwise, the matter turns on principlesof the law as to principal and agent. If the for-profit intermediary is functioningas an agent for the charitable organization, the full amount of thecontribution is deductible (not just the amount contributed net of the servicefee). If, however, the for-profit intermediary is serving as the agent of the donor,the charitable contribution deduction will not come into being until the giftmoney (or perhaps other property) is delivered by the intermediary to the charitableorganization. 80Because of delays in processing the gift, a donor may be placed in the positionof initiating the transaction late in a year, then find that the charitablededuction is not available until the subsequent year. 8178 Another illustration of these rules is available in Priv. Ltr. Rul. 200208019, concerning the federal tax consequencesof the making of a qualified conservation contribution (see § 9.7) by a partnership.79 See § 3.6, second bulleted item.80 Similar issues arise in the context of contributions of used vehicles. See § 9.23.81 In general, see § 10.7. Also see IRS Exempt Organization Continuing Professional Organization Text for FiscalYear 2000, Topic I, Part 1, § 4.B (concerning “third-party sites”). 185