Rev. Rul. 80-77
1980-1 C.B. 56, 1980-12 I.R.B. 8.
Internal Revenue Service
Revenue Ruling
CHARITABLE CONTRIBUTIONS
Published: March 24, 1980
26 CFR 1.170A-1: Charitable, etc., contributions and gifts; allowance of deductions.
Charitable contributions. Situations are presented in which payments to the Red Cross, a volunteer fire department, the Girl Scouts, and a combined charity fund are charitable contributions under section 170 of the Code.
ISSUE
Is a charitable contribution deduction allowable under section 170 of the Internal Revenue Code under the circumstances described below?
FACTS
Situation 1: A tornado destroys several homes in a town. The local chapter of the American National Red Cross provides food and temporary shelter to a taxpayer whose home was destroyed. The taxpayer, motivated by gratitude, makes a contribution of 5x dollars to the local chapter of the American National Red Cross.
Situation 2: A taxpayer owns a home in an area served by a volunteer fire department. No state or local taxes are used to support the fire department. The taxpayer makes a contribution of 5x dollars to the volunteer fire department's annual fund drive.
Situation 3: The taxpayer's daughter is a member of a local unit of the Girl Scouts of America. The taxpayer makes a contribution of 5x dollars to the Girl Scouts of America.
Situation 4: The taxpayer has a dependent parent who is a resident of a home for the elderly which is a member organization of a combined charity fund. The taxpayer makes an unrestricted contribution of 5x dollars to the combined charity fund that distributes the contributions to the member organizations according to a formula.
HOLDING
In each of the four situations, the taxpayer is allowed a charitable contribution deduction under section 170 of the Code, subject to the percentage limitations of section 170(b)(1).
Rev. Rul. 80-77, 1980-1 C.B. 56, 1980-12 I.R.B. 8.