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Tax Coda

Court trims claimed $132M charitable deduction

Barney v. Commissioner. T.C., No. 5310-22.

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Tax Coda
Jan 06, 2026
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Tax Court treated the 2012 transfer of Mr. Barney’s S corporation college group to a §501(c)(3) nonprofit as a bargain sale.

The court allowed a charitable deduction, but it sharply reduced the claimed values and left the final tax and penalty amounts for Rule 155 computations.

Holding

The court found the transferred S corporations had a collective fair m…

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