The IRS no longer considers any portion of a payment that earns seating priority deductible. What was "80/20" is now ZERO!
However, CASE has decided to allow institutions to COUNT these donations at 100% even when the IRS says they are not deductible.
However, you must still reduce the payment by the value of all tangible benefits.
CASE goes into all this in page 269 of the new 2nd edition.
John