Congressional Rationale

Research Project

Individuals who make contributions of appreciated tangible personal property to charitable organizations are subject to a limitation under section 170(e) of the Internal Revenue Code of 1986.  Section 170(e) purports to reduce the amount of charitable deductions by the amount of the property’s appreciation (or unrecognized gain) if the property’s use is unrelated to the charitable organization.

What was the Congressional rationale for this limitation in the Code?

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