Abstract
On December 8, 1970, the Smithsonian Institution received a ruling from the Internal Revenue Service stating that the Smithsonian is not a “private foundation” as defined in section 509(a) of the Internal Revenue Code but a “publicly supported” organization as described in section 170(b) (1) (A) of the Code. The Tax Reform Act of 1969 provides that individual donors may deduct contributions to “publicly supported” organizations in amounts up to 50 percent of the donor's contribution base for the taxable year. In the case of donations of personal property in which an appreciated value in excess of cost is claimed, the valuation of the donation is limited to 30% of the donor's contribution base.
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