§13172

* * * are not given out of any sense ofobligation or any sense offear that [Reverend Goodwin] will leave their parish ifhe is not compensated beyond his yearly salary." - 28 - [*28] See Omnibus Budget Reconciliation Act of 1993, Pub. L. No. 103-66, sec. 13172, 107 Stat. at 455 (adding section 170(f)(8) to the Code). Part ofthe more- or-less standard form language the Commissioner suggests is that "no goods or services were provided by the organization in return for the contribution." IRS Pub. 17

ed for the noncash contribution, not on the actual value of the property contributed. Id. at 13. That rule, focusing on the amount of the claimed deduction rather than the value of the property contributed, is supported by the legislative history of sec. 13172 of the Omnibus Budget Reconciliation Act of 1993, Pub. L. 103-66, 107 Stat. 445, which added para. (8) to sec. 170(f). See H. Rept. 103-111, at 563 (1993), 1993-3 C.B. 167, 441 (describing House bill provisions requiring substantiation for

13172, 107 Stat. 312. The House of Representatives proposed to enact section 170(f) due to Difficult problems of tax administration [that] arise with respect to fundraising techniques in which an organization that is eligible to receive tax deductible contributions provides goods or services in consideration for payments from donors. * * * the