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Chief Counsel Advice 201736023 Released September 8, 2017 Advice

Donor advised fund documentation met the written acknowledgment requirements

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This page covers one taxpayer's ruling from 2017, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

Currency note: this determination was released in 2017
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel reviewed whether a taxpayer had obtained the contemporaneous written acknowledgment required to substantiate a charitable deduction for a contribution to a donor advised fund. After reviewing additional information and discussing the facts and authorities, Counsel concluded that the sponsoring organization's documentation met the requirements cited in sections 170(f)(8)(C) and 170(f)(18)(b). The advice applies only to the documentation in this case.

Ruling snapshot

  • Question: Did the sponsoring organization's documentation satisfy the contemporaneous written acknowledgment requirements for the taxpayer's donor advised fund contribution?
  • Outcome: advice given
  • Key authorities: IRC §§ 170(f)(8)(C), 170(f)(18)(b)

Full text (IRS public release)

ID:        CCA_2017052209250619
UILC:      170.12-09

Number: 201736023
Release Date: 9/8/2017
From:
Sent: Monday, May 22, 2017 9:25:06 AM
To:
Cc:
Bcc:
Subject: -----------------------------------------


Hi ---------- – I’ve reviewed the additional information that you sent me and discussed the
facts and authorities with my reviewer regarding whether taxpayer complied with the
requirement to obtain a contemporaneous written acknowledgement for purposes of
substantiating its charitable deduction under the special requirements for contributions
to donor advised funds under §170(f). As we discussed on September 19th, we
believe the language in the sponsoring organization’s documentation meets the
requirements of both § 170(f)(8)(C) and § 170(f)(18)(b) for a contemporaneous written
acknowledgement in this case. Please let us know if you have further questions.

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