We have a donor who is insisting that he can use a DAF to pay for the charitable portion of a Gala sponsorship and pay the FMV of the tickets out of pocket. I have provided the DAF's documentation that this cannot be done, along with a second DAF's documentation stating the same thing. The donor wants to see the exact wording from the IRS. Can someone provide the exact publication and page where the IRS says that you cannot bifurcate a gift from a DAF? I am currently reading Code 4967 and I am not seeing what the donor wants to see.
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Sue Mathes
Dominican University
smathes@dom.edu------------------------------