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PERCENTAGE LIMITATIONSWhen a donor makes a gift of an undivided fractional interest in an item ofproperty 59 that is qualified capital gain property, the donee is a public charity,and the electable 50 percent limitation 60 is not elected, the amount of the gift isdetermined under this 30 percent limitation. The amount of the gift will equalthe product of (1) the fraction times (2) the fair market value of the entire item ofproperty at the time of the gift of the fractional interest. 61(b) Carryover RulesSubject to certain conditions and limitations, the excess of:The amount of the charitable contributions of capital gain property subject tothe 30 percent limitation made by an individual in a contribution year to publiccharitable organizationsdivided by:30 percent of the individual’s contribution base for the contribution yearis treated as a charitable contribution of capital gain property, subject to this 30percent limitation, paid by the individual to a public charitable organization ineach of the five tax years immediately succeeding the contribution year, in orderof time. 62 Also, any charitable contribution of capital gain property subject to the30 percent limitation that is carried over to these years under the general carryoverrules 63 is treated as though it were a carryover of capital gain propertyunder the special carryover rules 64 concerning this type of property. 65In 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 four amounts:1. The amount by which 30 percent of the donor’s contribution base for thesucceeding tax year involved exceeds the sum ofThe charitable contributions of capital gain property made (computedwithout regard to the carryover rules) by the donor in the year to publiccharitable organizations, andThe charitable contributions of capital gain property made to publiccharitable organizations in years preceding the contribution year which,pursuant to the contribution rules, are treated as having been paid to apublic charitable organization in the succeeding tax year involved.59See § 15.3.60See § 7.7.61E.g., Priv. Ltr. Rul. 9303007.62IRC § 170(b)(1)(C)(ii); Reg. § 1.170A-8(c)(1).63See § 7.8, text accompanied by note 105.64IRC § 170(b)(1)(C)(ii).65Reg. § 1.170A-10(c)(1). 200