Gray Corporation should defer the gift of the land until 2013. This would allow Gray to fully deduct in 2012 the carryover contribution amount of $75,000. If, instead, Gray gifted the land in 2012, the corporation would lose any otherwise allowable deduction as to the $75,000 carryover amount. This occurs because current year gifts are applied against the taxable income limitation before application of any carryover amounts. Thus, the taxable income limitation for 2012 would be completely exhausted by the gift of land in 2012. Since 2012 represents the fifth and last year of the carryover period, a gift of the land in 2012 precludes any deduction for the $75,000. A gift of appreciated land held for more than one year as an investment results in a charitable deduction equal to the land’s fair market value (subject to the taxable income limitation).