Contents

SPECIAL GIFT SITUATIONS(d) Substantiation Rules 315(e) Quid Pro QuoContribution Rules 316(f) Sales Tax Rules 316(g) Reporting Rules 317§ 9.14 Services 317§ 9.15 Unreimbursed Expenses 318(a) Exempt Functions 319(b) Inherent Nature ofServices 320(c) Substance of Services 320(d) Duration of Services 321(e) Excessive Expenditures 321(f) Element of Pleasure 322§ 9.16 Limitation on Deductionfor Expenses Dueto Pleasure 322(a) Substance of Services 322(b) Duration of Services 323(c) Element of Pleasure 324§ 9.17 Automobile Expenses 325§ 9.18 Use of Property 326§ 9.19 Bargain Sales 326(a) Definition ofBargain Sale 327(b) Allocation of Basis 327(c) Interplay with DeductionReduction Rule 329(d) Interplay withCarryover Rules 330§ 9.20 Property Subject to Debt 330§ 9.21 Future Interests inTangible PersonalProperty 333§ 9.22 Contributions by Trusts 336(a) General Rules 336(b) Gifts of Interests inProperties 337(c) Guaranteed AnnuityInterests 338(d) Unitrust Interests 340(e) Valuation 341(f) Recapture 341(g) Denial of Deductionfor CertainContributions 341§ 9.23 Partial Interests 342§ 9.24 Charitable FamilyLimited Partnerships 344§ 9.25 Used Vehicles 346§ 9.26 Intellectual Property 349§ 9.27 Foreign Tax Credit 350§ 9.28 Public PolicyConsiderations 351§ 9.1 WORKS OF ARTContributions of works of art may, of course, be made to charitable organizations.Works of art may also be loaned to these organizations.(a) GiftsIn general, the federal income tax charitable contribution deduction for a gift ofa work of art is an amount equal to the fair market value of the property. Thereare, however, exceptions to this general rule:1. The charitable deduction for any one year may be limited by one of thepercentage limitations. 12. The work of art that is contributed may be the creation of the donor, inwhich case the deduction is confined to the donor’s basis in the property. 21 See Chapter 7.2 IRC §§ 170(e)(1) and 1221. See § 9.12. 268