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PERCENTAGE LIMITATIONSin value and the charitable recipient is an entity other than a public charitableorganization.• These limitations are blended when the individual donor contributesmore than one type of item (money or property) in a tax year and/orgives to more than one type of charitable organization in a tax year.• Each of these percentage limitation rules allows for contributions inexcess of the limitation to be carried forward and deducted over the subsequentfive years, in order of time.• If a husband and wife file a joint return, the deduction for charitable contributionsis the aggregate of the contributions made by the spouses andthe percentage limitations are based on the aggregate contribution base ofthe spouses.• The charitable contribution deduction for a corporation for a tax year issubject to a limitation of 10 percent of the corporation’s pretax net income.• No percentage limitations apply in the estate tax or gift tax charitable contributiondeduction context. 10(c) Other Limitation RulesThere are two other limitation rules that are discussed elsewhere 11 but warrantmention at this point so that they can be correlated with the information in thischapter.• If an individual contributes an item of tangible personal property that hasappreciated in value to a public charitable organization, but the publiccharity does not use the property for a purpose that is related to its taxexemptpurposes, the donor must reduce the deduction by the entirety ofthe capital gain element.• When an individual makes a contribution of an item of appreciated propertyto a charitable organization that is not a public charitable organization,the donor must reduce the deduction by all of the capital gainelement.§ 7.2 INDIVIDUAL’S CONTRIBUTION BASEThe percentage limitations used in ascertaining the deductibility of charitablegifts are applied, in the case of individuals, to an amount equal to the donor’scontribution base. 12 The term contribution base means the individual’s adjustedgross income, 13 computed without regard to any net operating loss carryback 14to the tax year. 15 For most individuals, the amounts constituting the contributionbase and adjusted gross income are the same.10 See Chapter 8.11 See §§ 4.5-4.7.12 IRC § 170(b)(1)(F).13 IRC § 62.14 IRC § 172.15 Reg. § 1.170A-8(e). 190