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activities allocated annuity trust apply appreciated property bargain sale basis benefit business taxable income cash charitable contribution deduction charitable gift charitable lead trust charitable organizations charitable remainder trust Code Section community foundations Congress contribution base corporation death debt financed determined distribution donor election estate tax example excess exclusion exempt organization exempt purposes fair market value Federal foreign organization gift annuity gift tax governing instrument grant grantor included Income Fund Trust income interest income tax income trust individual Internal Revenue Service investment itemized deductions minimum tax ordinary income organiza organization's payment percent limitation percentage Pooled Income Fund private foundation public charity publicly supported organizations qualify rate of return received regulations remainder interest remainderman requirements Revenue Ruling status substantial Tax Reform Act tax-exempt taxpayer tion trade or business transfer U.S. organization unitrust amount units unrelated business taxable unrelated trade valuation date