That seems right to me. In addition to the gift revenue, you have non-gift revenue that exceeds the cost of the premium.
This arises because the IRS looks at this from the perspective of the donor and what the donor would otherwise have paid to obtain the hat, so the non-gift part of the transaction is based on the Fair Market Value (FMV), not the cost, while the cost is based on, well, the cost! There's no reason that those would match, and, in fact, would only match if you paid FMV for the hat.
One could make an argument that the net revenue could also support the fundraising objective, along with the gift part, I would think, but that's a matter for internal discussion.
My US$0.02 worth; the usual disclaimers apply.
Good luck!
Alan
Alan S. Hejnal (he/him)
Data Quality Manager
