Advanced Individual Taxation
Noncash Charitable Contributions and Foundations
Worth 15 points
Look at Romney’s 2011 Form 8283
1. What amount of deduction did Romney take for noncash charitable contributions? $920,573_____
2. What type of organization is the Tyler Charitable Foundation? (has now become Romney Foundation for Children)
· public charity, private operating foundation or private nonoperating foundation
3. Is the deduction valued at adjusted basis or fair market value? __FMV______________
4. Assuming the donation was capital gain property, what is the maximum amount of charitable deduction Romney would have been allowed in 2011 for this type of donation (show the calculation)? _______
AGI=$13,696,951 * 20%= $2,739,390
5. Section A, Part 1, Column (h) indicates “Method used to determine the fair market value.” For Romney’s contributions, there is a reference to TR REG #20.2031-2 (Treas. Reg. Sec. 20.2031-2). Find and cut & paste below the relevant reference from the Regulations. (Hint: Within Regulations, paragraphs are lower case letters and subparagraphs are numbers and I am expecting part of a subparagraph. Include only the relevant sentences.) (See CCH instructions for accessing authority.)
(1) In general, if there is a market for stocks or bonds, on a stock exchange, in an over-the-counter market, or otherwise, the mean between the highest and lowest quoted selling prices on the valuation date is the fair market value per share or bond.
6. For the contributions to Dunkin Brands and Sensata indicate:
a. The price per share used to value the contribution. Dunkin: $25.45 Sensata: $32.15
b. Based on the Regulation, how was the price calculated? (I want the actual mathematical calculation.)
Dunkin: High on 11/16/2011=$25.84 Low on 11/16/2011=$25.06
The mean of 25.84 and 25.06=$25.45 * 8,600 shares= $218,870 FMV
Sensata: High on 2/17/2011=$33.41 Low on 2/17/2011=$30.89
The mean of 33.41 and 30.89=$32.15 * 7,243 shares= $232,863 FMV
Hint: To find stock prices, first find the company’s website, then find investor relations, and then look for historic stock lookup.
Look at Clinton’s 2014 charitable contributions:
7. How much and to what organization was Clinton’s largest cash charitable contribution?
$3,000,000 to the Clinton Family Foundation
8. What type of organization is it?
· public charity, private operating foundation or private nonoperating foundation
Look at Fiorina’s 2013 Form 8283:
9. How much and to what organization was Fiorina’s largest noncash charitable contributions? $249,854 to Ayco Charitable Foundation_________________
10. What type of organization is it?
· public charity, private operating foundation or private nonoperating foundation
