TREATMENT OF CERTAIN AMOUNTS PAID TO OR FOR THE BENEFIT OF AN INSTITUTION OF HIGHER EDUCATION.

SEC. 6001. TREATMENT OF CERTAIN AMOUNTS PAID TO OR FOR THE BENEFIT OF AN INSTITUTION OF HIGHER EDUCATION. (a) In General.—Section 170 of the 1986 Code is amended by redesignating subsection (m) as subsection (n) and by inserting after subsection (1) the following new subsection: “(m) Treatment of Certain Amounts Paid to or for the Benefit of Institutions of Higher Education.— 102 STAT. 3684 “(1) In general.—For purposes of this section, 80 percent of any amount described in paragraph (2) shall be treated as a charitable contribution. “(2) Amount described.— For purposes of paragraph (1), an amount is described in this paragraph if— “(A) the amount is paid by the taxpayer to or for the benefit of an educational organization— “(i) which is described in subsection (b)(1)(A)(ii), and “(ii) which is an institution of higher education (as defined in section 3304(f)), and “(B) such amount would be allowable as a deduction under this section but for the fact that the taxpayer receives (directly or indirectly) as a result of paying such amount the right to purchase tickets for seating at an athletic event in an athletic stadium of such institution. If any portion of a payment is for the purchase of such tickets, such portion and the remaining portion (if any) of such payment shall be treated as separate amounts for purposes of this subsection.” (b) Effective Date.— (1) In general.—The amendment made by this section shall apply to taxable years beginning after December 31, 1983. (2) Waiver of statute of limitations.—If on the date of the enactment of this Act (or at any time within 1 year after such date of enactment) refund or credit of any overpayment of tax resulting from the application of section 170(m) of the 1986 Code (as added by subsection (a)) is barred by any law or rule of law, refund or credit of such overpayment shall, nevertheless, be made or allowed if claim therefore is filed before the date 1 year after the date of the enactment of this Act,