Friday, September 11, 2009
A republishing of my earlier Mory's posting in the daily email update distributed by Paul Streckfus, the Editor of the EO Tax Journal, generated this additional information from a Connecticut reader:
"The answer is that the club is not the charity, but a separate trust designed to support the certified historic structure within which the club operates. Contributions to Mory's Trust would be tax deductible as 'qualified conservation contributions' under section 170(h) of the Code; note that among the conservation purposes provided in subsection (4)(A) of that section is "(iv) the preservation of an historically important land area or a certified historic structure. The arrangement utilized by Mory's is not at all unusual, and numerous clubs with historic structures have acted likewise. The result is often the reconstruction and renovation of historic structures which, in many cases, were deteriorating."
My thanks to Paul for making this response available.