Читать книгу The Tax Law of Charitable Giving - Bruce Hopkins R., Bruce R. Hopkins, David Middlebrook - Страница 90

A charitable contribution made by means of an irrevocable banker's letter of credit is the basis of a charitable deduction as of the date the letter of credit was established. This is because an irrevocable letter of credit from a bank is the equivalent of money.⁴⁶

In one instance, an individual established an irrevocable banker's letter of credit in favor of a charitable organization. The letter of credit was for an aggregate amount of $150,000, payable by drafts drawn by the charity. The entire $150,000 was distributed to the charitable organization in four amounts, one in the year the letter of credit was established and the other three in the subsequent year. The IRS ruled that the entire $150,000 was deductible by this individual for the year in which the letter of credit was established, because the full amount was made available without restriction to the charitable organization. The fact that the charity withdrew only a portion of the amount available during the first year was held to be immaterial, because the charitable organization could have withdrawn the entire amount.⁴⁷