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PERCENTAGE LIMITATIONSEXAMPLE 7.14This example is based on the facts of Example 7.13. A was allowed a charitable contributiondeduction for 2005 of $30,000 (30% of $100,000) and a carryforward of $15,000 ($45,000 −$30,000).§ 7.9 INTERPLAY OF 50 PERCENT/SPECIAL30 PERCENT LIMITATIONSIn computing the charitable contribution deduction, contributions of money topublic charitable organizations are taken into account before contributions ofcapital gain property to public charitable organizations.This rule is illustrated by the following two examples:EXAMPLE 7.15H and W (husband and wife) had a contribution base for 2005 of $50,000 and for 2006 of$40,000, and filed a joint return for both years. In 2005, H and W contributed $20,000 inmoney and $13,000 of capital gain property to PC, a public charitable organization. In 2006,they contributed $5,000 in cash and $10,000 of capital gain property to PC. They were able toproperly claim a charitable contribution deduction of $25,000 for 2005. The excess of $33,000(contributed to PC) over the $25,000 (50% of contribution base), or $8,000, constituted acharitable contribution carryover, which was treated as a charitable contribution of capital gainproperty (subject to the 30 percent limitation) paid by them to a public charitable organizationin each of the five succeeding tax years in order of time. Because 30 percent of the contributionbase for H and W for 2006 ($12,000) exceeded the charitable contribution of capital gainproperty ($10,000) made by them in 2006 to a public charitable organization (computedwithout regard to the carryover rules), the portion of the 2005 carryover equal to the excess of$2,000 ($12,000 − $10,000) was treated as paid to a public charitable organization in 2006.The remaining $6,000 constituted an unused charitable contribution carryover in respect ofcapital gain property subject to the 30 percent limitation from 2005. aaReg. § 1.170A-10(c)(1), Example (1).EXAMPLE 7.16This example is based on the facts of Example 7.15, except that the $33,000 of charitablecontributions in 2005 was all of capital gain property. Because the charitable contributions ofH and W in 2005 exceeded 30 percent of their contribution base ($15,000) by $18,000($33,000 − $15,000), they were able to claim a charitable contribution deduction of $15,000in 2005; the excess of $33,000 over $15,000 ($18,000) constituted a charitable contributioncarryover, which was treated as a charitable contribution of capital gain property (subject to the30 percent limitation) paid by them to a public charitable organization in each of the fivesucceeding tax years in order of time. Because they were allowed to treat only $2,000 of their2005 contributions as paid in 2006, H and W had a remaining unused charitable contributioncarryover of $16,000 in respect of capital gain property subject to the 30 percent limitationfrom 2005. aaReg. § 1.170A-10(c)(1), Example (2).§ 7.10 INTERPLAY OF 50 PERCENT/GENERAL30 PERCENT LIMITATIONSWhen an individual donor makes, in the same year, gifts of money and/orcapital gain property to one or more public charitable organizations and giftsof money in circumstances involving the general 30 percent limitation, the 208

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