Charitable Deduction

ID:
Office:
UILC:
CCA_2009052116214139
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642.03-00
Number: 200928029
Release Date: 7/10/2009
From: ---
Sent: Thursday, May 21, 2009 4:21:45 PM
To: ---
Cc:
Subject: RE: Rev Rul. 2004-5
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---forwarded your question on to me. The answer is as follows: Rev. Rul. 2004-5 does permit trusts to claim charitable contributions made by a partnership of which the trust is a partner, even if the trust instrument does not provide for charitable contributions. However, the Rev. Rul. does not eliminate a second requirement that this charitable contribution be made out of the trust's gross income. Therefore, the contribution of the easement does cannot be claimed as a charitable contribution.
Please feel free to give me a buzz if you need more details.
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