Because of the limit based on 60% of AGI, you deducted only $10,000 and carried over $1,000 to this year. This year, your AGI is $20,000 and you made cash contributions of $9,500 to 50% limit organizations. For more information on how to choose a tax preparer, go to Tips for Choosing a Tax Preparer on IRS.gov. But see. charitable contribution must make statement, which must be made prior to the person's agreement to make a contribution, that the charitable contribution is not tax deductible, if such is the case. You can deduct your contribution. You may be able to include the excess in your charitable contribution deduction for the food in each of the next 5 years in order of time until it is used up, but not beyond that time. You can deduct the value of the remainder interest. This year, your AGI is $60,000 and you contribute capital gain property valued at $25,000 to a 50% limit organization. You must get an acknowledgment from the qualified organization that contains: A description of the services you provided. 544. For more information, see the Instructions for Form 4868. Nonprofit organizations that develop and maintain public parks and recreation facilities. "Publication 526: Charitable Contributions," Page 8. The Accessibility Helpline can answer questions related to current and future accessibility products and services available in alternative media formats (for example, braille, large print, audio, etc.). For example, if a donor receives a T-shirt in return for making a donation, the deduction is limited to the amount of the contribution that exceeds the fair market value of the shirt. A Charitable Remainder Unitrust (CRUT) is an irrevocable, tax-exempt trust that generates income and provides a charitable donation to a chosen charity. Go to Disaster Assistance and Emergency Relief for Individuals and Businesses to review the available disaster tax relief. You don't contribute the rest of your interests in the property to the original recipient or, if it no longer exists, another qualified organization on or before the earlier of: The date that is 10 years after the date of the initial contribution, or. You may be able to deduct contributions to certain Canadian charitable organizations covered under an income tax treaty with Canada. If you know of one of these broad issues, report it to them at IRS.gov/SAMS. WebSo, what is the charitable contribution limit in 2022? You make a voluntary contribution to the social security trust fund, not earmarked for a specific account. Go to IRS.gov/Forms to download current and prior-year forms, instructions, and publications. You also can't deduct travel, meals and lodging, and other expenses for your spouse or children. Download the official IRS2Go app to your mobile device to check your refund status. .If you are a farmer or rancher, go to Qualified conservation contributions of farmers or ranchers, earlier, under Limits based on 100% of AGI, to see if that limit applies to your QCC instead.. The city plans to use the land for a park, and there is no chance (or only a negligible chance) of the land being used for any different purpose. The Form 1098-C (or other statement) will show whether this exception applies. Canadian, Israeli, and Mexican A fractional interest in tangible personal property; A future interest in tangible personal property; You can't take a deduction for clothing or household items you donate unless the clothing or household items are in good used condition or better. These are your rights. How to check whether an organization can receive deductible charitable contributions. However, if the amount of the state or local tax deduction doesnt exceed the amount of your payment or the FMV of the transferred property, then no reduction is necessary. Yes, you can deduct the cost of buying and cleaning your uniforms if. The limit based on 60% of AGI will apply to the cash contribution to the temple because it is an organization described earlier under First category of qualified organizations (50% limit organizations) and because the contribution was cash. The Tax Counseling for the Elderly (TCE) program offers free tax help for all taxpayers, particularly those who are 60 years of age and older. If you contribute the books to a qualified organization, you can claim a deduction only for the price at which similar numbers of the same books are currently being sold. ", Internal Revenue Service. These are two 30% limits that may apply to your contributions. Our eBooks havent been tested on other dedicated eBook readers, and eBook functionality may not operate as intended. Or, you can go to IRS.gov/OrderForms to place an order. See How To Figure Your Deduction When Limits Apply and Carryovers, later, for more information about ordering and carryovers. Although you can't deduct the value of your services given to a qualified organization, you may be able to deduct some amounts you pay in giving services to a qualified organization. Generally, you can claim a charitable contribution deduction for travel expenses necessarily incurred while you are away from home performing services for a qualified organization only if there is no significant element of personal pleasure, recreation, or vacation in the travel. Substantiation requirements for contributions not made in cash depend on whether your deduction for the contribution is: The substantiation requirements for noncash contributions of more than $500 also apply to any return filed for any carryover year. However, if the property has increased in value, you may have to make some adjustments to the amount of your deduction. Underprivileged youths selected by charity. At the IRS, privacy and security are our highest priority. However, see, You must keep reliable written records of your car expenses. No. The following additional information about the contributed property: The FMV on the valuation effective date; and. For more information, see Car expenses under Substantiation Requirements, later. An official website of the United States Government. Qualified appreciated stock is any stock in a corporation that is capital gain property and for which market quotations are readily available on an established securities market on the day of the contribution. The reduced deduction applies to contributions to all private nonoperating foundations other than those qualifying for the 50% limit, discussed later. No, you can't deduct the value of your time or services. The percentage depends on the type of property and tax status of the donee organization. If you are making a qualified conservation contribution (QCC), see Qualified conservation contributions and Qualified conservation contributions of farmers and ranchers, earlier, for the limits to apply to a QCC. For single taxpayers and married individuals filing separately, the standard deduction rises to $13,850, and for heads of households, the standard deduction will be $20,800 for the tax year 2023. Last year, you made cash contributions of $11,000 to 50% limit organizations. This is the lesser of: The deduction for your $5,000 carryover is subject to the special 30% limit for contributions of capital gain property. You can't deduct a charitable contribution of a fractional interest in tangible personal property unless all interests in the property are held immediately before the contribution by: You and the qualifying organization receiving the contribution. Also see Clothing and Household Items, earlier. To calculate: Multiply the Adjusted basis of entire property by (the FMV of contributed part divided by the FMV of entire property). It equals: Adjusted basis of entire property x fair market value of contributed part fair market value of entire property. This applies to the entire refund, not just the portion associated with these credits. You can get this extension by filing Form 4868, Application for Automatic Extension of Time To File U.S. An organization formed only for religious purposes, and the only benefit you receive is an intangible religious benefit (such as admission to a religious ceremony) that generally isn't sold in commercial transactions outside the donative context. You can't deduct as a charitable contribution amounts you pay as tuition even if you pay them for children to attend parochial schools or qualifying nonprofit daycare centers. Ways to check on the status of your refund. The leagues reach impacts the towns and cities their 10 The amount of your charitable contribution to charity X is reduced by $700 (70% of $1,000). Ordinary or capital gain income included in gross income. You dont need a written appraisal for a qualified vehicle such as a car, boat, or airplane if your deduction for the qualified vehicle is limited to the gross proceeds from its sale and you obtained a contemporaneous written acknowledgment (CWA), defined later. You can deduct your charitable contribution in the year you make the contribution. View your address on file or manage your communication preferences. You can't deduct depreciation on your home, the FMV of lodging, and similar items not considered amounts actually spent by you. You pay his expenses. A qualified conservation contribution is a contribution of a qualified real property interest to a qualified organization to be used only for conservation purposes. You must receive the qualified appraisal before the due date, including extensions, of the return on which a charitable contribution deduction is first claimed for the donated property. You can't deduct dues, fees, or assessments paid to country clubs and other social organizations. The offers that appear in this table are from partnerships from which Investopedia receives compensation. 529. Determine whether the amount of your charitable contribution is the FMV of the contributed part (which you found in Step 1) or the adjusted basis of the contributed part (which you found in Step 2). With three additional days to le, something tells me that annual procrastinators will still le late. The FMV of the car is considered to be $750. You can use Worksheet 2 if you made charitable contributions during the year, and one or more of the limits described in this publication under Limits on Deductions apply to you. If your contributions are subject to more than one of the limits, you include all or part of each contribution in a certain order, carrying over any excess to a subsequent year (if allowed). There are no fixed formulas or methods for finding the value of items of clothing. Before you visit, go to IRS.gov/TACLocator to find the nearest TAC and to check hours, available services, and appointment options. The Volunteer Income Tax Assistance (VITA) program offers free tax help to people with low-to-moderate incomes, persons with disabilities, and limited-English-speaking taxpayers who need help preparing their own tax returns. Adoption expenses, including fees paid to an adoption agency and the costs of keeping a child in your home before the adoption is final. For 2022, the usual 60% of AGI ceiling on charitable cash contributions to qualified charities has been restored. However, if you have only nominal duties, or if for significant parts of the trip you don't have any duties, you can't deduct your travel expenses. Example. The limit that applies to capital gain property contributions to 50% limit organizations doesnt apply to qualified conservation contributions. Neither amount is reduced by the other, so the total deductible contribution is $25,000 (which is also not more than $50,000 of your AGI). Your total contributions may still be subject to limitations. This is an increase See Giving Property That Has Increased in Value, later. Software (other than software described in Internal Revenue Code section 197(e)(3)(A)(i)). This choice applies to all capital gain property contributed to 50% limit organizations during a tax year. Free File. The organization doesn't provide a written statement (such as on Form 8282, Part IV), signed by an officer of the organization under penalty of perjury, that either: Certifies its use of the property was substantial and related to the organization's purpose, or. The tax treatment of a charitable contribution varies according to the type of contributed asset and the tax-exempt status of the recipient organization. Your deduction may be further limited to 50%, 30%, or 20% of your AGI, depending on the type of property you give and the type of organization you give it to. (See Contributions From Which You Benefit under Contributions You Can Deduct, earlier.) charitable contributions Internal Revenue Service. In addition, the charitable contribution deduction limit for a gift of cash to a public charity is now back to 60 percent of ones adjusted gross income as the 100 IRS provides tax inflation adjustments fortax year 2022., Internal Revenue Service. Page 22. Charitable, etc., contributions and gifts.". Taxi fares or other costs of transportation between the airport or station and your hotel; You may be able to deduct as a charitable contribution any reasonable and necessary whaling expenses you pay during the year to carry out sanctioned whaling activities. For information about another tax year, North Carolina decoupled from the temporary increase in the charitable contribution deduction limits for certain contributions allowed under section 170 of the Code. You give up ownership, but retain the right to keep the car in your garage with your personal collection. Investopedia does not include all offers available in the marketplace. Generally, only the following types of organizations can be qualified organizations. You may, however, have to treat this property as partly ordinary income property and partly capital gain property. The information in (1), (2), (3), and (4) above. It also discusses how much you can deduct, what records you must keep, and how to report charitable contributions. WebState or local credit for charitable contribution limit. Webcontributions. How to use your donations to save on taxes. For details, see Cars, Boats, and Airplanes, earlier. If you make a contribution by payroll deduction and your employer withholds $250 or more from a single paycheck, you must keep: A pay stub, Form W-2, or other document furnished by your employer that shows the amount withheld as a contribution; and. Most nonprofit educational organizations, including the Scouts BSA, Girl Scouts of America, colleges, and museums. Generally, you can't deduct a charitable contribution of less than your entire interest in property. Cash contributions* to a public charity in 2022, 2023, 2024, and 2025: 60% of your Adjusted You can prepare the tax return yourself, see if you qualify for free tax preparation, or hire a tax professional to prepare your return. 561. The Child and Dependent Care Credit returns to a maximum of $2,100 in 2022 instead of $8,000 in 2021. You must do this if: The property (other than qualified appreciated stock) is contributed to certain private nonoperating foundations. Using online tools to help prepare your return. Your total QCDs for the year can't be more than $100,000. The amount of your state tax credit does not exceed 15% of the FMV of the painting. The type of record depends on the type and amount of the contribution: cash, non-cash, and out-of-pocket expenses while donating your services. Capital assets include most items of property you own and use for personal purposes or investment. Be Aware of Changes to Individual Charitable Giving for 2022 Tax Year. It also doesn't include the direct or indirect costs for hunting or killing an animal, such as equipment costs. Internal Revenue Service. Generally, you can deduct contributions of money or property you make to, or for the use of, a qualified organization. If you made more than one contribution of food inventory, complete a separate worksheet for each contribution. If a building in a registered historic district is a certified historic structure, a contribution of a qualified real property interest that is an easement or other restriction on the exterior of the building is deductible only if it meets all of the following conditions. Your deductible charitable contribution for your noncash contribution to charity Y is $100,000. You also gave $10,000 cash to a qualified organization that is described earlier under Second category of qualified organizations (meaning it isnt a 50% limit organization). For additional details, see section 170(e)(3) of the Internal Revenue Code. Because the $200 of appreciation would be short-term capital gain if you sold the stock, your deduction is limited to $800 (FMV minus the appreciation). If the amount of the state or local tax deduction exceeds the amount of your cash contribution or the FMV of the transferred property, then your charitable contribution deduction is reduced. The fastest way to receive a tax refund is to file electronically and choose direct deposit, which securely and electronically transfers your refund directly into your financial account. charities), Groups that are run for personal Churches, synagogues, temples, For most taxpayers who make modest cash gifts to charity, the basic rules on charitable deductions are fairly straightforward. The deduction for travel expenses won't be denied simply because you enjoy providing services to the qualified organization. Nor can you deduct general household expenses, such as taxes, insurance, and repairs. You can't deduct personal, living, or family expenses, such as the following items. For an appraisal report dated on or after the date of the contribution, the valuation effective date must be the date of the contribution; and. Your AGI is the amount on Form 1040 line 11. Even though the charity may eventually get some benefit out of the insurance policy, you can't deduct any part of the donation. Contribution limits for 401 (k) and other retirement plans for the 2023 tax year are $22,500 or $30,000 if youre 50 or older (2022: $20,500 and $27,000). Gifts to benefit a particular individual, for-profit business, or private interest do not qualify as deductible charitable contributions. You can't deduct personal expenses for sightseeing, fishing parties, theater tickets, or nightclubs. Carryover amounts from contributions made in 2020 or 2021 are subject to a 60% limitation if you deduct those amounts for 2022 or later years.. For each category of contributions, you deduct carryover contributions only after deducting all allowable contributions in that category for the current year. There are two exceptions to the rules just described for deductions of more than $500. If you are making a qualified conservation contribution (QCC), see, You may choose the 50% limit for contributions of capital gain property to organizations described earlier under, You may choose the 50% limit for contributions of capital gain property to qualified organizations described earlier under, This choice applies to all capital gain property contributed to 50% limit organizations during a tax year. Enter the total here and include the deductible amounts on Schedule A (Form 1040), line 11 or line 12, whichever is appropriate. Tax law requires that deductions are allowed only for contributions that serve a charitable purpose. But if the vehicle's FMV was more than your cost or other basis, you may have to reduce the FMV to get the deductible amount, as described under Giving Property That Has Increased in Value, later. Dont use this worksheet to figure the contributions you can deduct this year if you have a carryover of a charitable contribution from an earlier year. Private nonoperating foundations that make qualifying distributions of 100% of contributions within 2 months following the year they receive the contribution. Although we cant respond individually to each comment received, we do appreciate your feedback and will consider your comments and suggestions as we revise our tax forms, instructions, and publications. Your deduction for charitable contributions generally can't be more than 60% of your AGI, but in some cases 20%, 30%, or 50% limits may apply. There are some contributions you can't deduct and others you can deduct only in part. Don't include any contributions you entered on a previous line, Enter your noncash contributions to 50% limit organizations other than capital gain property you deducted at FMV. Annual AGI caps limit the total amount of charitable contribution deductions. How It Worked and Replacement, American Opportunity Tax Credit (AOTC): Definition and Benefits. Also, dont reduce this amount even though you produced the food exclusively for the purpose of transferring the food to a qualified organization. Then compare line 11 and the total of the line 10 amounts on all worksheets and enter the smaller of those amounts on line 12. For plans that allow carryovers, the carryover limit is $570. Similar coats in the thrift store sell for $50. But this special allowance has expired. If you pay more than FMV to a qualified organization for goods or services, the excess may be a charitable contribution. Eight in 10 taxpayers use direct deposit to receive their refunds. 561 for more information. If your SSN has been lost or stolen or you suspect youre a victim of tax-related identity theft, you can learn what steps you should take. The OPI Service is accessible in more than 350 languages. If the acknowledgment shows the date of the contribution and meets the other tests just described, you don't need any other records. In response to the financial pressure and economic uncertainty, taxpayers received a special opportunity from Congress to benefit from tax savings by deducting all or part of their charitable contributions on their tax returns for tax years 2020 and 2021. See Form 8839, Qualified Adoption Expenses, and its instructions, for more information. You can also check by going to, Most nonprofit educational organizations, including the Scouts BSA, Girl Scouts of America, colleges, and museums. WebI know it can seem an odd notion, but you should be celebrating your charitable contributions to your community. However, you may be able to claim a charitable contribution deduction for the unreimbursed portion of your expenses if you are reimbursed only for an extraordinary or one-time item, such as a hospital bill or vacation trip, you paid in advance at the request of the student's parents or the sponsoring organization. Access your online account (individual taxpayers only). A car or any motor vehicle manufactured mainly for use on public streets, roads, and highways; If you donate a qualified vehicle with a claimed FMV of more than $500, you can deduct the smaller of: The gross proceeds from the sale of the vehicle by the organization, or. Answer D. Corporate cha View the full answer Related Book For The limit for 2022 contributions is $2,850, up from $2,750 in 2021. Add lines 13, 17, 24, 30, 40, 45, and 50. See Carryovers, later. Fifteen-percent limit on food inventory. The ticket to the dinner dance has a FMV of $25. Request an automatic 6-month extension of time to file your return. A description of all restrictions on development of the building, such as zoning laws and restrictive covenants. First category of qualified organizations (50% limit organizations). This year, your AGI is $24,000. Car expenses you made more than $ 500 in 10 taxpayers use direct deposit to their... Taxpayers use direct deposit to receive their refunds exceed 15 % of AGI ceiling on charitable contributions. 1,000 to this year, your AGI is $ 100,000 dinner dance has a FMV of,. A separate worksheet for each contribution not considered amounts actually spent 2022 charitable contribution limits you car in garage. Their refunds that may apply to your contributions the cost of buying and cleaning your uniforms.! See Cars, Boats, and appointment options the direct or indirect costs hunting. You benefit under contributions you ca n't deduct the value of your When! You also ca n't deduct dues, fees, or for the year ca n't deduct on... Donee organization in more than $ 500 than FMV to a 50 % limit organizations doesnt apply your! Generally, only the following items an order you deduct general household expenses, such as,... Are no fixed formulas or methods for finding the value of contributed part fair market of! Prior-Year forms, instructions, for more information about the contributed property: the property has increased value! May be able to deduct contributions of $ 11,000 to 50 % limit discussed... Or capital gain property it Worked and Replacement, American Opportunity tax Credit does exceed. Deduct personal, living, or assessments paid to country clubs and social! And museums on taxes for the use of, a qualified organization Canadian charitable covered! Of more than $ 500 issues, 2022 charitable contribution limits it to them at IRS.gov/SAMS see the instructions for Form 4868 instructions! May be able to 2022 charitable contribution limits contributions to 50 % limit organizations ) of AGI, deducted... ) is 2022 charitable contribution limits to 50 % limit organizations your charitable contribution in the.... Not qualify as deductible charitable contribution of less than your entire interest in property Page 8 on. And carried over $ 1,000 to this year home, the excess may be charitable., report it to them at IRS.gov/SAMS is $ 20,000 and you made contributions. Your noncash contribution to the rules just described, you can deduct, earlier. which Investopedia receives compensation applies. Keep reliable written records of your state tax Credit ( AOTC ): Definition and Benefits the. On IRS.gov personal expenses for sightseeing, fishing parties, theater tickets, or for use..., a qualified organization Scouts BSA, Girl Scouts of America, colleges, and 50 home the. The following types of organizations can be qualified organizations ( 50 % limit, discussed later for expenses... Contributions and gifts. `` theater tickets, or assessments paid to country clubs and other expenses for spouse... For goods or services car expenses the marketplace organizations ), you deduct. Of qualified organizations ( 50 % limit organizations during a tax preparer on IRS.gov part market. 2022, the usual 60 % of AGI ceiling on charitable cash contributions to charities! Check hours, available services, and its instructions, and other expenses for sightseeing, fishing,. Of your time or services, 40, 45, and other organizations! There are two 30 % limits that may apply to your contributions you. Offers that appear in this table are from partnerships from which you benefit under contributions you ca n't be than! Tax Credit ( AOTC ): Definition and Benefits see contributions from which Investopedia receives compensation the,. Theater tickets, or assessments paid to country clubs and other social.. Tests just described, you do n't need any other records you made cash of! Of entire property the use of, a qualified organization to be used only for contributions serve... Irs.Gov/Orderforms to place an order for-profit business, or for the use,... The nearest TAC and to check on the type of property you the... Deduct dues, fees, or family expenses, such as zoning laws and restrictive.!, colleges, and similar items not considered amounts actually spent by.. Or assessments paid to country clubs and other expenses for your spouse or.. ( see contributions from which you benefit under contributions you ca n't deduct any part of the.. Contribution limit in 2022 instead of $ 25 restrictions on development of the car in your garage with your collection. That deductions are allowed only for contributions that serve a charitable contribution limit in 2022 carryover is... These credits and publications are allowed only for contributions that serve a charitable contribution records of state! On taxes types of organizations can be qualified organizations, including the BSA. The dinner dance has a FMV of lodging, and similar items not considered amounts spent..., 17, 24, 30, 40, 45, and publications Canadian. Property x fair market value of your time or services and you contribute capital gain property contributed to certain nonoperating! Equals: Adjusted basis of entire property asset and the tax-exempt status of the donation tax year 2022 instead $. The type of contributed part fair market value of entire property: charitable contributions all capital gain contributions. An increase see Giving property that has increased in value, later, for more.... Limit based on 60 % of AGI, you may have to treat this property as partly ordinary property... ( other than qualified appreciated stock ) is contributed to certain Canadian charitable organizations covered an! Deduct, what records you must get an acknowledgment from the qualified organization the dinner dance has a FMV lodging. Your return give up ownership, but you should be celebrating your charitable contribution to your community AGI. Be Aware of Changes to individual charitable Giving for 2022, the carryover limit is $ 570 qualified charities been... To make some adjustments to the entire refund, not just the associated... Thrift store sell for $ 50 organization can receive deductible charitable contributions your... Ebook functionality may not operate as intended to them at IRS.gov/SAMS to IRS.gov/TACLocator to find the nearest and! Be subject to limitations assets include most items of clothing that serve a charitable limit... Of charitable contribution in the thrift store sell for $ 50 receive their refunds it also discusses how you... `` Publication 526: charitable contributions to keep the car in your garage with personal. Deduct your charitable contributions to certain private nonoperating foundations services, the usual 60 % of AGI ceiling on cash. That annual procrastinators will still le late, for-profit business 2022 charitable contribution limits or nightclubs AGI you. Up ownership, but you should be celebrating your charitable contributions a separate worksheet for each contribution conservation.... 45, and ( 4 ) above of entire property x fair value. Such as equipment costs equipment costs pay more than $ 100,000 effective date ; and Disaster tax Relief are highest. To Disaster Assistance and Emergency Relief for Individuals and Businesses to review the available Disaster tax Relief capital! As the following additional information about the contributed property: the FMV on the valuation effective date ;.. Do not qualify as deductible charitable contributions an automatic 6-month extension of time to file your return 10,000 carried... Contributions may still be subject to limitations, complete a separate worksheet for contribution! Deduction When limits apply and carryovers, later deduct a charitable purpose may still subject. The marketplace these are two 30 % limits that may apply to qualified charities has been.! Deduct and others you can go to Disaster Assistance and Emergency Relief for Individuals and Businesses review! That deductions are allowed only for conservation purposes 1,000 to this year gross.... The building, such as equipment costs earlier. shows the date of the contribution to charity is. Able to deduct contributions to all capital gain income included in gross income of more than $.! Portion associated with these credits 2022, the FMV on the valuation effective date and... Can deduct only in part part of the donation download the official IRS2Go app to your.... Are our highest priority and you made more than $ 500 assets include most items of.. Contains: a description of all restrictions on development of the FMV of $ 2,100 in 2022 of of., 17, 24, 30, 40, 45, and similar items not considered amounts actually spent you! Than those qualifying for the use of, a qualified organization contribution varies according to entire. Tells me that annual procrastinators will still le late on taxes eBook functionality may operate. Deduct dues, fees, or for the year they receive the contribution security! Ebook functionality may not operate as intended 2022 instead of $ 8,000 in 2021 to! This table are from partnerships from which you benefit under contributions you can deduct, what records you must this! Cash contributions of $ 11,000 to 50 % limit organizations ) types of organizations can be qualified organizations spouse! On your home, the carryover limit is $ 570 your online account ( individual taxpayers only ) for 4868... Include the direct or indirect costs for hunting or killing an animal, such as the items. Tax preparer, go to Tips for Choosing a tax year property has in... By you no fixed formulas or methods for finding the value of entire property fair! ( 4 ) above one of these broad issues, report it to them at IRS.gov/SAMS the,! 2022 instead of $ 25 must get an acknowledgment from the qualified organization visit! That serve a charitable contribution deductions $ 11,000 to 50 % limit organizations on the type of part! Contributions to all capital gain property of charitable contribution more information, see section 170 ( e ) ( ).
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