Charitable, Etc. Contributions and Gifts

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 200552011
Release Date: 12/30/2005
CC:ITA:B02:GMatuszeski
POSTN-149431-05
UILC: 170.00-00 date: September 22, 2005 to: ---
Internal Revenue Service
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Income Tax & Accounting subject: Technical Advice Memorandum Transmittal
Taxpayer/TIN: ---
CASE MIS No.: TAM-170491-03 Year(s) or Period(s) Involved: 1995, 1996, 1997, 1998
Attached is our memorandum in response to your request for technical advice in the case named above.
The attached memorandum comes within the scope of § 6110 of the Code and, accordingly, will be made open to public inspection in the Freedom of Information Reading Room, except in cases involving criminal investigations, civil fraud investigations, or jeopardy or termination assessments. This will normally occur 75-90 days after the date of mailing of the enclosed “Notice of Intention to Disclose” and the redacted copy of the technical advice memorandum to the taxpayer. These documents must be furnished to the taxpayer within 30 calendar days after the technical advice memorandum is mailed from the National Office, unless the IRS office to which the technical advice memorandum is addressed seeks reconsideration. The Notice of Intention to Disclose, Notice 438, must be appropriately dated in accordance with the instructions furnished by the National Office; the date of mailing of the Notice must be documented; and a copy of the Notice (containing the dates inserted by you) must be immediately forwarded with an accompanying transmittal memorandum containing the name of the taxpayer, to the National Office, c/o Chief, Disclosure Unit, CC:PA:T:DU, Ben Franklin Station, Post Office Box 7604, Washington, D.C. 20044.
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POSTN-149431-05 2
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Case returned for further development. State reasons below or continue on a separate sheet, if

necessary.
Attachments:
Copy of this memorandum
Original and two copies of Technical Advice
Memorandum
Distribution:
You must check appropriate blocks. Copies of this memorandum and Technical Advice Memorandum to:
Operating Division
Copy of Technical Advice Memorandum edited for
6110 purposes
Copy of Notice of Intention to Disclose
Copy of Technical Advice Dating Schedule
Submitting office case file (if any) cc: Virginia L. Hamilton, Attorney, LMSB
Robin L. Herrell, Senior Counsel, LMSB
SBSE LMSB TEGE WI
Appeals
Headquarters and Area Office
WI LMSB SBSE-TEGE
Division Counsel
SBSE LMSB TEGE WI