IRS FAA: Disallowance of Non-Cash Charitable Deduction in Purported Bargain Sale of Property (IRC §170)

No charitable deduction under I.R.C. §170 is permitted with respect to a purported bargain sale of property as there was no intent to make a charitable donation and there was nothing of value to contribute once the property was acquired by the buyer, the Chief Counsel’s Office advised. The Form 8283, Noncash Charitable Contributions, reflects that the sale to the buyer was by an entity that was ultimately wholly owned by the seller. [FAA 20233201F]