PLR 200743033: Gifts to federal agency deductible for public purposes

Number

200743033

Outcome

Approved

Document type

Private Letter Ruling

IRS subject

Governmental Units

Topics

Income and deductions

Code sections

§ 170

Ruling dated

July 30, 2007

Publicly released

October 26, 2007

Source

View Official PDF

Apply this to your situation

This page covers one taxpayer's ruling, issued in 2007, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.

About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.

Transcribed from a scanned original: the IRS released this determination as an image-only PDF. The full text below is a machine transcription, proofread against the scan. Check the original PDF before quoting exact language.

View official IRS release (PDF)

Plain-English summary

A federal agency asked whether it could receive charitable contributions deductible to donors. The agency received a congressional appropriation and was authorized to solicit and accept gifts on behalf of the United States. The IRS confirmed that, as a federal agency, it could receive contributions deductible under section 170(c)(1) when they were made for exclusively public purposes. The ruling ties deductibility to how the gift is used.

Ruling snapshot

Question: Are gifts to the federal agency deductible to contributors?
Outcome: Yes, if made for exclusively public purposes.
Key authorities: IRC § 170(c)(1).

Full text (IRS public release)

DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224

TAX EXEMPT AND
GOVERNMENT ENTITIES
DIVISION

Release Number: 200743033
Release Date: 10/26/07

Date: July 30, 2007 Contact Person:
XXXXXXXXXX
Identification Number:
XXXXXXXXXXXXXXXXXXXXXXXKXKXXXXXXXXXXKXKKK XXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXX Telephone Number:
XXXXXXXXXXXXXXXXXXXXXXXKX XXXXXXXXXXXXX

Attn: xxXXXXXXXXXXXXX,

Employer Identification Number: xxxxxxxxxx

Uniform Issue List:
170.07-05

Legend:
M =
N =
O =

Dear :

This is in response to your request that we confirm that you are eligible to receive tax- deductible charitable contributions under section 170(c)(1) of the Internal Revenue Code.

You are a Federal agency of the United States Government established pursuant to the M, et. seq. You receive an annual appropriation from the United States Congress. N. You are authorized to solicit, accept and receive gifts, bequests, or devises of money and other property or services in the name of the United States. O.

As a federal agency of the United States government, you are eligible to receive charitable contributions that are tax-deductible to contributors under section 170(c)(1) of the Code if made for exclusively public purposes.

This ruling is directed only to the organization that requested it. Section 6110(k)(3) of the Code provides that it may not be used or cited by others as precedent.

-2-

If there are any questions about this ruling, please contact the person whose name and telephone number are shown in the heading of this letter.

Sincerely,

Robert C. Harper, Jr.
Manager, Exempt Organizations
Technical Group 3

Enclosure
Notice 437

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