This is a really arbitrary number. How is it justified by the statute? I think the section is IRC 170. I noticed the following strange line in there
BEGIN QUOTE
(E) Regulations The Secretary shall prescribe such regulations as may be necessary or appropriate to carry out the purposes of this paragraph, including regulations that may provide that some or all of the requirements of this paragraph do not apply in appropriate cases.
END QUOTE
Ie, looks like they're saying the regulations can violate the statute if appropriate?