---
kind: "section"
citation: "26 U.S.C. § 84"
title: "26"
title_heading: "Internal Revenue Code"
number: "84"
heading: "Transfer of appreciated property to political organizations"
release: "119-102"
date: "2026-07-12"
url: "https://uscodex.org/usc/26/84"
units:
  - "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. Transfer of appreciated property to political organizations

- (a) **General rule—** If—
  - (1) any person transfers [property](/usc/26/317.md?p=a) to a political [organization](/usc/26/414.md?p=m-6-A), and
  - (2) the fair market [value](/usc/26/851.md?p=c-4) of such [property](/usc/26/317.md?p=a) exceeds its adjusted basis,

  then for purposes of this chapter the transferor shall be treated as having sold such [property](/usc/26/317.md?p=a) to the political [organization](/usc/26/414.md?p=m-6-A) on the date of the transfer, and the transferor shall be treated as having realized an amount equal to the fair market [value](/usc/26/851.md?p=c-4) of such [property](/usc/26/317.md?p=a) on such date.

- (b) **Basis of property—** In the case of a transfer of [property](/usc/26/317.md?p=a) to a political [organization](/usc/26/414.md?p=m-6-A) to which [subsection (a)](#a) applies, the basis of such [property](/usc/26/317.md?p=a) in the hands of the political [organization](/usc/26/414.md?p=m-6-A) 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](/usc/26/414.md?p=m-6-A)” has the meaning given to such term by [section 527(e)(1)](/usc/26/527.md?p=e-1).

## Source credit

(Added Pub. L. 93–625, § 13(a)(1), Jan. 3, 1975, 88 Stat. 2120; amended Pub. L. 115–141, div. U, title IV, § 401(a)(35), Mar. 23, 2018, 132 Stat. 1186.)

## Notes

### 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.