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Title 26, Internal Revenue CodeRelease 119-110

§84 Transfer of Appreciated Property to Political Organizations

Title 26 › 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

Last updated Sep 22, 2026|Official source

Summary

If a person gives property to a political organization and the property's fair market value is higher than its adjusted basis, the giver is treated for tax purposes as if they sold the property on the day they gave it. The giver must count the fair market value as the amount they realized. The political organization’s tax basis in the property is the giver’s basis increased by the gain the giver had to recognize. "Political organization" means the same as in section 527(e)(1).

Full Legal Text

Title 26, §84

Internal Revenue Code, Source: USLM XML via OLRC

(a)General rule
If—
(1)any person transfers property to a political organization, and
(2)the fair market value of such property exceeds its adjusted basis,
then for purposes of this chapter the transferor shall be treated as having sold such property to the political organization on the date of the transfer, and the transferor shall be treated as having realized an amount equal to the fair market value of such property on such date.
(b)Basis of property
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)Political organization defined
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

Sep 22, 2026

Release point: 119-110