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§ 9.21 FUTURE INTERESTS IN TANGIBLE PERSONAL PROPERTYEXAMPLE 9.13The facts are the same as in Example 9.11, except that A died without relinquishing his right tothe use, possession, and enjoyment of the painting. Because A did not relinquish his right to theuse, possession, and enjoyment of the property during his life, A is treated as not having made acharitable contribution of the painting for income tax purposes. aaReg. § 1.170A-5(b), Example (3).EXAMPLE 9.14The facts are the same as in Example 9.11, except that A, on December 31, 2006, transferredhis interest in the painting to his daughter, B. Because A and B are related, no contribution ofthe remainder interest in the painting is considered to have been made in 2006. aaReg. § 1.170A-5(b), Example (4).EXAMPLE 9.15The facts are the same as in Example 9.14. On December 31, 2007, B conveys to themuseum the interest measured by A’s life. B thus makes a charitable contribution of thepresent interest in the painting conveyed to the museum. In addition, because all interveninginterests in, and rights to the actual possession or enjoyment of, the property have expired, acharitable contribution of the remainder interest is treated as having been made by A in 2007,for which a charitable contribution deduction is allowable (without regard to the partialinterest gift rules). The value of the remainder interest is determined by subtracting the valueof B’s interest measured by A’s life expectancy in 2007, and B receives a charitablecontribution deduction in 2007 for the life interest measured by A’s life expectancy. aaReg. § 1.170A-5(b), Example (5).EXAMPLE 9.16On December 31, 2005, C, an individual, transfers a valuable painting to a qualified pooledincome fund a maintained by a university. C retains for himself, for life, an income interest in thepainting and contributes the remainder interest in the painting to the university. Because thecontribution consists of a future interest in tangible personal property in which the donor hasretained an intervening interest, no charitable deduction is considered to have been made in2005. baSee Chapter 13.bReg. § 1.170A-5(b), Example (6).EXAMPLE 9.17On January 15, 2005, D, an individual transfers a painting (a long-term capital asset) to apooled income fund maintained by a university, and creates an income interest in the paintingfor E, for her life. D and E are not related individuals. D contributes the remainder interest in theproperty to the university. The trustee of the pooled income fund puts the painting to anunrelated use. a Accordingly, D is allowed a charitable deduction in 2005 for the present valueof the remainder interest in the painting (after reducing the amount as required). b This reductionin the amount of the contribution is required because the pooled income fund’s use of thepainting would have been an unrelated use if it had been made by the university. caSee § 3.5.bId.cReg. § 1.170A-5(b), Example (7). 335