Title 26, Internal Revenue CodeRelease 119-73
§84 Transfer of Appreciated Property to Political Organizations
Title 26 › Subtitle Subtitle A— Income Taxes › Chapter 1— NORMAL TAXES AND SURTAXES › Subchapter B— Computation of Taxable Income › Part II— ITEMS SPECIFICALLY INCLUDED IN GROSS INCOME › § 84
Summary
When you give property to a political organization and the property is worth more than your adjusted basis in it, you are treated as recognizing gain on the transfer. The political organization then takes your basis in the property, increased by the gain you recognized. A political organization here means the same thing as in section 527(e)(1).
Full Legal Text
Title 26, §84
Internal Revenue Code, Source: USLM XML via OLRC
(a)If—
(1)any person transfers property to a political organization, and
(2)the fair market value of such property exceeds its adjusted basis,
(b)In the case of a transfer of property to a political organization to which subsection (a) applies, the basis of such property in the hands of the political organization shall be the same as it would be in the hands of the transferor, increased by the amount of gain recognized to the transferor by reason of such transfer.
(c)For purposes of this section, the term “political organization” has the meaning given to such term by section 527(e)(1).
Legislative History
Notes & Related Subsidiaries
Editorial Notes
Amendments
2018—Pub. L. 115–141 substituted “political organizations” for “political organization” in section catchline.
Statutory Notes and Related Subsidiaries
Effective Date
Pub. L. 93–625, § 13(b), Jan. 3, 1975, 88 Stat. 2121, provided that: “The
Amendments
made by subsection (a) [enacting this section] shall apply to transfers made after
May 7, 1974, in taxable years ending after such date.” Nonrecognition of Gain or Loss Where Organization Sold Contributed Property Before
August 2, 1973 Pub. L. 93–625, § 13(c), Jan. 3, 1975, 88 Stat. 2121, provided that in the case of the sale or exchange of property before Aug. 2, 1973, which was acquired by the exempt political organization by contribution, no gain or loss shall be recognized by such organization.
Reference
Citations & Metadata
Citation
26 U.S.C. § 84
Title 26, Internal Revenue Code
Last Updated
Apr 6, 2026
Release point: 119-73