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PERCENTAGE LIMITATIONSto 2006. Because application of the net operating loss carryover of $50,000 from 2004reduced the 2005 adjusted gross income (for purposes of determining 2005 tax liability) to zero,no part of the $25,000 of charitable contributions in 2005 was deductible, under thepercentage limitation rules for individuals. In determining the amount of the excess charitablecontributions to be treated as paid in tax years 2006, 2007, 2008, 2009, and 2010, however,the $30,000 must be reduced to $5,000 by the portion of the excess charitable contributions($25,000) that was used to reduce taxable income for 2005 (as computed for purposes of thegeneral rule concerning net operating loss carryovers) and that thereby increased the netoperating loss carryover to 2006 from zero to $25,000. aaReg. § 1.170A-10(d)(1), Example (1).EXAMPLE 7.22 (CONTINUED)EXAMPLE 7.23The facts of this example are the same as those in Example 7.22, except that B’s total charitablecontributions of $30,000 in money made during 2005 consisted of $25,000 to publiccharitable organizations and $5,000 to other charitable organizations. There was a tentativeexcess charitable contribution of $25,000, rather than $30,000 as in Example 7.22. Forpurposes of determining the net operation loss that remained to be carried over to 2006, Bcomputed his taxable income for 2005 under the general rule concerning net operating losscarryovers by deducting the $25,000 of charitable contributions to public charitableorganizations. Because the excess charitable contribution of $25,000 was used to reducetaxable income for 2005 (as computed for purposes of this general rule) and thereby increasedthe net operating loss carryover to 2006 from zero to $25,000, no part of the excess charitablecontributions made in the contribution year could be treated as paid in any of the fiveimmediately succeeding tax years. A carryover was not allowed with respect to the $5,000 ofcharitable contributions made in 2005 to the other charitable organizations. aaReg. § 1.170A-10(d)(1), Example (2).EXAMPLE 7.24This example is based on the facts in Example 7.23, except that B’s total charitablecontributions of $30,000 made during 2005 were of capital gain property subject to the 30percent limitation. There was a tentative excess charitable contribution of $30,000. Forpurposes of determining the net operating loss that remained to be carried over to 2006, Bcomputed his taxable income for 2005 under the general rule concerning net operating losscarryovers by deducting the $15,000 (30% of $30,000) contribution of capital gain propertythat would have been deductible in 2005 absent the net operating loss deduction. Because$15,000 of the excess charitable contribution of $30,000 was used to reduce taxable incomefor 2005 (as computed for purposes of this general rule) and thereby increased the netoperating loss carryover to 2006 from zero to $15,000, only $15,000 ($30,000 − $15,000) ofthe excess could be treated as paid in tax years 2006, 2007, 2008, 2009, and 2010. aaReg. § 1.170A-10(d)(1), Example (3).(b) Carryback RulesThe amount of the excess charitable contribution for a contribution year may notbe increased because a net operating loss carryback is available as a deduction inthe contribution year. 214