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§ 7.14 BLENDING PERCENTAGE LIMITATIONSgain property to public charitable organizations that are allowable underthe 30 percent limitation. 103This 20 percent limitation applies to contributions of property when theamount of the gift, for deduction purposes, was reduced under the deductionreduction rules. 104(b) Carryover RulesIn general, the excess of:The amount of the charitable contribution or contributions of capital gainproperty made by an individual in a contribution year to one or more charitableorganizations that are not public charitable organizationsdivided by:20 percent of the individual’s contribution base for the contribution yearis treated as a charitable contribution paid by the individual to a nonpublic charitableorganization, subject to the 20 percent limitation, in each of the five taxyears immediately succeeding the contribution year, in order of time. 105EXAMPLE 7.21The facts of this example are the same as in Example 7.20. A had a carryforward of $5,000 tobe treated as a gift of capital gain property to charitable organizations that are not publiccharitable organizations for years subsequent to 2005.§ 7.13 GIFTS FOR THE USE OF CHARITYThe federal income tax law provides for a charitable contribution deduction forgifts to or for the use of one or more qualified charitable donees. 106 Charitablecontributions discussed in other sections of this chapter are gifts to a charitableorganization. Contributions for the use of a charitable organization are discussedelsewhere. 107Contributions for the use of a charitable organization are subject to the general30 percent limitation. 108§ 7.14 BLENDING PERCENTAGE LIMITATIONSA donor who is an individual may make gifts of various types to charitable organizationsof various tax classifications in a single year. These gifts may be partlyof money and partly of property. The property may or may not be capital gainproperty. The charitable donees may be public charities, private foundations,veterans’ organizations, or other charitable recipients. The law provides forapplication of the various percentage limitations in situations in which differing103Id.104Id. The deduction reduction rules are the subject of §§ 4.5-4.7.105IRC § 170(b)(1)(D)(ii).106IRC § 170(c).107See § 10.3.108IRC § 170(b)(1)(B). 211