Section 170 C 2

The department of the treasury treasury department and the internal revenue service irs are aware that some promoters are syndicating conservation easement transactions that purport to give investors the opportunity to obtain charitable contribution deductions.

Section 170 c 2. 109 280 which directed the amendment of section 170 without specifying the act to be amended were executed to this section which is section 170 of the internal revenue code of 1986 to reflect the. Internal revenue code section 170 c 2 charitable etc contributions and gifts. Sections 1202 a 1204 a 1206 a b 1 1213 a d 1214 a b 1215 a 1216 a 1217 a 1218 a 1219 c 1 and 1234 a of pub.

Listing notice syndicated conservation easement transactions. 1 a state a possession of the united states or any political subdivision of any of the foregoing or the united states or the district of columbia but only if the contribution or gift is made for exclusively public purposes. A private foundation cannot make a grantfor a purpose not described in section 170 c 2 b of the internal revenue code.

C charitable contribution defined. 2 to claim a charitable contribution deduction a taxpayer must establish that he or she made a gift to a qualified entity organized and operated exclusively for an exempt purpose no part of the net earnings of which inures to the benefit of any private shareholder or individual. Ii providing for the determination of an amount to be treated as net income of the donee which is properly allocable to qualified intellectual property in the case of a donee who uses such property to further a purpose or function constituting the basis of the donee s exemption under section 501 or in the case of a governmental unit any purpose described in section 170 c and does not possess a right to receive any payment from a third party with respect to such property.

170 a 2 b payment of such contribution is made after the close of such taxable year and on or before the 15th day of the fourth month following the close of such taxable year then the taxpayer may elect to treat such contribution as paid during such taxable year. Permitted purposes are religious charitable scientific literary or educational fostering national or international amateur sports competition but only if no part of the activities involve providing athletic facilities or equipment and preventing cruelty to children or animals.