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covering all of the gifts or by a separate acknowledgment for each gift. See Treas.
Reg. section 1.170A-13(f)(1). The $250 threshold applies separately to separate
gifts, and no contemporaneous acknowledgment is required for separate
contributions of less than $250 each, even if the sum of the taxpayer’s
contributions to the donee organization during the taxable year equals $250 or
more. See id.

If the donor’s payment is distributed to another charity, the initial payee is
usually treated as the donee for this purpose, even if the ultimate recipient of the
funds is designated by the taxpayer. See Treas. Reg. section 1.170A-13(f)(12).
However, if the ultimate recipient provides goods or services to the taxpayer and
the payment is put through the intermediate charity in an attempt to avoid a
reduction of the taxpayer’s deduction for the value of the goods or services, the gift
is deemed made to the ultimate recipient, not the intermediate charity.

The contemporaneous acknowledgment must state the amount of a cash

contribution and provide a description, but not a valuation, of donated property
other than cash. See Code section 170(f)(8)(B). It must also state whether the
donee organization provided any goods or services in consideration for the
contribution and, if so, it must include a description and good faith estimate of the
value of these goods or services. However, no contemporaneous acknowledgment
is required if, after subtracting the value of the goods and services, the charitable
gift is less than $250. See Treas. Reg. section 1.170A-13(f)(1).

If the donee organization provides any intangible religious benefits, the
acknowledgment must contain a statement to that effect. See Code section
170(f)(8)(B)(iii). An “intangible religious benefit” is a benefit provided by an
organization organized exclusively for religious purposes that generally is not sold

in a commercial transaction outside the donative context. See Code section
170(f)(8)(B). An example is admission to a religious ceremony. See H.R. Rep. No.
213, 103d Cong., 1st Sess. 566. Tuition for education leading to a recognized
degree, travel services, and consumer goods are not intangible religious benefits
unless they are de minimis and incidental to a religious ceremony (e.g., communion
wine). See id. at n.34.

The acknowledgment need not contain the donor’s taxpayer identification
number. See H.R. Rep. No. 213, 103d Cong., 1st Sess. 565 n.30. No particular form
is required, and the acknowledgment may consist, for example, of a letter,
postcard, or computer-generated form. See id. at n.32. An acknowledgment is
contemporaneous if the taxpayer obtains it no later than the date on which the

WASHINGTON NONPROFIT HANDBOOK -158- 2018