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United States v. American Bar Endowment, 477 U.S. 105 (1986)

To be recognized as a charitable contribution for federal tax purposes, donors must at a minimum demonstrate that they purposely transferred money or property to a qualifying charitable organization in excess of the value of any benefit received in return. That is the standard (the "excess value test") set by the United States Supreme Court in the 1986 American Bar Endowment (the "ABE") decision, which described the sine qua non of a charitable contribution as a transfer of money or property without adequate consideration.