Get Revenue Ruling 1996-1 - Section 170.-Charitable, Etc., Contributions And Gifts. Valuation Of A

501(c)(3) organizations may take one of three primary structures: public charities, private foundations, and private operating foundations.

Internal Revenue Code Section 170(b)(1)(A) There shall be allowed as a deduction any charitable contribution (as defined in subsection (c) ) payment of which is made within the taxable year. A charitable contribution shall be allowable as a deduction only if verified under regulations prescribed by the Secretary.

Section 509(a) (also referred to as Section 170(b)) of the Internal Revenue Code designates a 501(c)(3) organization's public charity/private foundation status, which is determined by the nature of the organization or types of financial support it receives.

An educational organization is described in section 170(b)(1)(A)(ii) if its primary function is the presentation of formal instruction and it normally maintains a regular faculty and curriculum and normally has a regularly enrolled body of pupils or students in attendance at the place where its educational activities ...

§170(c), Charitable Contribution Defined A State, a possession of the United States, or any political subdivision of any of the foregoing, or the United States or the District of Columbia, but only if the contribution or gift is made for exclusively public purposes.

Section 170 provides that contributions to certain types of organizations—primarily 501(c)(3)s and a few others—are deductible by the donor as itemized deductions. Section 501(c)(3) governs tax exemption of organizations, while section 170 governs deductibility of contributions by individuals.

Section 170(a) provides, subject to certain limitations, a deduction for any charitable contribution, as defined in § 170(c), payment of which is made within the taxable year. Section 170(f)(3) denies a charitable contribution deduction for certain contributions of partial interests in property.

Section 170(c)(3) of the Code includes within the term "charitable contribution" as used in section 170 a contribution or gift to or for the use of a post or organization of war veterans, or an auxiliary unit or society of, or trust or foundation for, any such post or organization that is organized in the United States ...