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Nonprofit Law/lumpsum donation from multiple donors out of 1 account


Let's say 50 donors contribute $1 each to a 501c3 campaign by putting their money in a piggy bank, and only 1 individual takes that piggy bank money, then makes a lumpsum donation to the 501c3 via a $50 check.  Does only this individual get the charitable contribution deduction, and is it for $50 - even if he only really contributed $1 like all the others?  This scenario happens a lot in the workplace, where one colleague pools all the cash.  It is also common now with crowdsource fundraising where many people contribute online to 1 person's PayPal account for a specific 501c3 campaign - but the accounting trail only shows that 1 person's donation from their PayPal to our 501c3 PayPal account, for example.  Who gets the tax receipt and for how much?

The 501(c)(3) organization would acknowledge the donation from the person or company that made the payment to the organization.  As to charitable deductions, see IRS Publication 526 "Charitable Donations"  which is available at
on page 18, "You can claim a deduction for a contribution of $250 or more only if you have an acknowledgment of  your contribution from the qualified organization or certain payroll
deduction records."

So, if there is a payroll deduction, even though the company is making the payment to the 501(c)(3) organization, then, in that case, the individual would get the deduction, but not otherwise. As for donations below $250 the individuals may take the deduction as they like, as long as they keep some evidence of the donation even through a middle-man, as long as that middle man is legally obligated to forward the funds to the charity. In Davis v. United States, 495 U.S. 472 (1990), the Supreme Court provided guidance for the first time on the issue of whether
payments made "to or for the use of" a qualified organization were deductible as charitable contributions under IRC 170(c).

The court then ruled,
--- Start of Excerpt ---
Accordingly, we conclude that a gift or contribution is "for the
use of" a qualified organization when it is held in a legally
enforceable trust for the qualified organization or in a similar
legal arrangement.
---End of Excerpt---

Harvey Mechanic, Attorney at Law -

P.S. This response is intended to be a general statement of law, should not be relied upon as legal advice and does not create an attorney/client relationship.  

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Harvey Mechanic


DO NOT GIVE ME INFORMATION THAT YOU WANT KEPT CONFIDENTIAL. I am an attorney and I volunteer time to answer general questions about U.S. Federal income tax issues of nonprofit 501(c)(3) public charities only. Those questions could be about establishing and maintaining legal requirements for such non-profit organizations in the United States, including Internal Revenue service filings and requirements. I will not be working on this free forum to answer questions about Nonprofit's possible unrelated or for-profit businesses or how to fill out forms. This forum is only for general questions about federal tax law, not as the law applies to your specific situation. If you do not make your question public then I will not be spending much of my donated time on answers that would not benefit the public. If you have other questions, please contact me at I will reply from my email. In any case, do not reveal confidential information to me until after I have contracted with you to provide personal legal services. My responses on this forum are intended to be general statements of law, should not be relied upon as legal advice, and do not create an attorney/client relationship. For me to consider your individual situation and how the law applies, I would need to gather extensive information about the situation. To search my previous answers you can do a Google search by "" without the quotes and then add your search terms before hitting enter.


I have been practicing law and especially the law of nonprofit organizations since 1990 when I was admitted to the New York Bar and I have maintained my status with the Bar since that time.


B.S. Columbia University in New York City, 1970

J.D. (Law Degree) Brooklyn Law School, 1990 -- Cum Laude.

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