⁷Assumes birth date of Jan. 1, 1929, annual 5% payout made at the end of each year, 3.8% interest rate, based on 120% of the applicable Federal midterm rate for April 2004; see Rev. Rul. 2004-39, IRB 2004-14.

⁸Planned-giving techniques are typically more advantageous for older taxpayers, because the contributions deductible portion increases with age.

⁹See Rev. Procs. 92-49, 1992-1 CB 987 and 90-12, 1990-1 CB 471.

¹⁰John C. Todd, 118 TC 334 (2002); see Swift, Limits on Individuals Charitable Deductions (Part I), 35 The Tax Adviser 296 (May 2004).

¹¹Certain itemized deductions are reduced by 3% of AGI over a threshold of $142,700 for 2004. Those deductions subject to the overall limit cannot be reduced by more than 80%; see Sec. 68(a) and Rev. Proc. 2003-85, IRB 2003-49, 1184.

¹²The following states do not impose an income tax on individuals: Alaska, Florida, Nevada, South Dakota, Texas, Washington and Wyoming.