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§ 7.5 FIFTY PERCENT LIMITATIONThese rules may be illustrated by the following two examples:EXAMPLE 7.3The facts are the same as in Example 7.1, except that A made charitable contributions of moneyto public charitable organizations totaling $55,000. She was allowed a charitable contributiondeduction for 2005 of $50,000 (50% of $100,000) and the balance of $5,000 was carriedforward, to be used in the subsequent five years, beginning in 2006.EXAMPLE 7.4H and W had a contribution base for 2005 of $50,000 and for 2006 of $40,000, and filed ajoint tax return for both years. In 2005, H and W made a charitable contribution of money in theamount of $27,000 to PC (a public charitable organization). In 2006, they made a charitablecontribution in money of $15,000 to PC. They were able to properly claim a charitablecontribution deduction of $25,000 in 2005 (50% of $50,000) and the excess of $2,000($27,000 – $25,000) constituted a charitable contribution carryover, which was subsequentlytreated by them as a charitable contribution paid by them to a public charitable organization ineach of the five succeeding tax years in order of time. Because 50 percent of their contributionbase for 2006 ($20,000) exceeded the charitable contribution of $15,000 made by them in2006 to PC (computed without regard to the carryover rules), the 2005 carryover amount of$2,000 was treated as paid to a public charitable organization in 2006. Thus, H and W had a$17,000 federal income tax charitable contribution deduction for 2006.In applying these rules, the amount of the excess contributions that are to betreated as paid to a public charitable organization in any one of the five tax yearsimmediately succeeding the contribution year may not exceed the lesser of thefollowing three amounts:1. The amount by which 50 percent of the donor’s contribution base for thesucceeding tax year involved exceeds the sum of:The charitable contributions actually made (computed without regardto the carryover rules) by the donor in the year to public charitableorganizations, andThe charitable contributions, other than contributions of capital gainproperty to which the 30 percent limitation applies, 50 made to publiccharitable organizations in years preceding the contribution yearwhich, pursuant to the carryover rules, are treated as having been paidto a public charitable organization in the succeeding tax year involved.2. In the case of the first tax year succeeding the contribution year, theamount of the excess charitable contribution in the contribution year.3. For the second, third, fourth, and fifth tax years succeeding the contributionyear, the portion of the excess charitable contribution in the contributionyear that has not been treated as paid to a public charitable organization in50 See § 7.6. 195