I was sceptical, but case laws says that is correct; a transfer of an appreciated asset is not an assignment of income. HAROLD N. SHELDON, 62 TC 96, 04/25/1974
"An operating farmer who donates crops to a charity before he recognizes income from them is not required to include the value of the crops in his income.2 The farmer has merely assigned to the charity a property asset which has appreciated in value. Neither the harvesting nor the donative transfer of the product of his capital and services is a taxable event. See Campbell v. Prothro, 209 F.2d 331 (C.A. 5, 1954); Stuart A. Rogers, 38 T.C. 785 (1962); and White v. Brodrick, 104 F.Supp. 213 (D.Kan. 1952), appeal dismissed per curiam 198 F.2d 751 (C.A. 10, 1952); cf. Tatum v. Commissioner, 400 F.2d 242, 246-247 (C.A. 5, 1968), affirming"