Journal of Taxation
The PPA radically changes the rules applicable to charitable gifts of fractional interests in tangible personal property. The new rules are exceptionally onerous and there, unless modified, are likely to discourage donors from making fractional interest contributions.
In general, the Code does not allow a deduction for income, gift or estate tax purposes for a donation to charity of an interest in property that consists of less than the taxpayer's entire interest in the property. Nevertheless, a deduction is permitted for a contribution of an interest in property that consists of a "vertical slice" of the taxpayer's interest, such as an undivided interest (e.g., 40%) of the taxpayer's interest in the property
Diana S.C. Zeydel, Mitchell M. Gans, and Jonathan G. Blattmachr,
What Estate Planners Need To Know About The New Pension Protection Act, 105 J. Tax'n 199
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