OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
December 21, 2001
Acting Manager, Stamp Services United States Postal Service
475 L'Enfant Plaza, SW, Room 5670
Washington, DC 20260-2435
Dear Mr. Failor:
Commissioner Rossotti has asked me to respond to your inquiry regarding
the deductibility of amounts paid for postage stamps issued pursuant to the
9/11 Heroes Stamp Act of 2001, Pub. L. No. 107-67, § 652, 111 Stat.
In order to afford the public a direct and tangible way to
provide assistance to the families of emergency relief personnel killed or
in the line of duty in connection with the terrorist attacks against the
United States on September 11, 2001, the 9/11 Heroes Stamp Act directs the
United States Postal Service to issue special first-class postage stamps
(Heroes stamps), to be sold for an amount at least 15 percent greater than
the regular rate of first-class postage. The excess is to be transferred
to the Federal Emergency Management Agency (FEMA).
When a taxpayer, with the intention of making a gift, purchases an item
of value from a qualified charity, the excess of the payment over the value
received is a charitable contribution. Accordingly, taxpayers who purchase
a Heroes stamp from the United States Postal Service are entitled to treat
as a charitable contribution the difference between the price of the Heroes
stamp, and the price of regular first-class postage.
If you have any further questions, please contact Sean Dwyer at (202) 622-5020.
Kimberly L. Koch
Acting Chief, Branch 1
Associate Chief Counsel
(Income Tax & Accounting)