Reg. § 25.2522(c)-2 Disallowance of charitable, etc., deductions in the case of gifts made after December 31, 1969.
(a) Organizations subject to section 507(c) tax Section provides that, in the case of gifts made after December 31, 1969, a deduction which would otherwise be allowable under section for a gift to or for the use of an organization upon which the tax provided by section has been imposed shall not be allowed if the gift is made by the donor after notification is made under section or if the donor is a substantial contributor (as defined in section ) who makes such gift in his taxable year (as defined in section ) which includes the first day on which action is taken by such organization that culminates in the imposition of the tax under section and any subsequent taxable year. This paragraph does not apply if the entire amount of the unpaid portion of the tax imposed by section is abated under section by the Commissioner or his delegate.
(b) Taxable private foundations, section 4947 trusts, etc Section provides that, in the case of gifts made after December 31, 1969, a deduction which would otherwise be allowable under section shall not be allowed if the gift is made to or for the use of—
(1) A private foundation or a trust described in section in a taxable year of such organization for which such organization fails to meet the governing instrument requirements of section (determined without regard to section (B) and (C)), or
(2) Any organization in a period for which it is not treated as an organization described in section by reason of its failure to give notification under section of its status to the Commissioner.
For additional rules, see (Income Tax Regulations).
(c) Foreign organizations with substantial support from foreign sources Section provides that, in the case of gifts made after December 31, 1969, a deduction which would otherwise be allowable under section for a gift to or for the use of a foreign organization which has received substantially all of its support (other than gross investment income) from sources without the United States shall not be allowed if the gift is made
(1) after the date on which the Commissioner has published notice that he has notified such organization that it has engaged in a prohibited transaction, or
(2) in a taxable year of such organization for which it is not exempt from taxation under section because it has engaged in a prohibited transaction after December 31, 1969.
[T.D. 7318, 39 FR 25458, July 11, 1974]