A donor’s right to direct title of an historic theater to an organization other than the 501(c)(3) charitable recipient of a bargain sale invalidates the gift and is grounds to deny a claim for a $3 million charitable contribution deduction, the Tax Court has held. George Fakiris was a 60% owner in Grou Development LLC, a New York City real estate owner and developer. In 2001, Grou acquired the St. George Theatre in Staten Island, originally opened in 1929, for $700,000. The building, which had been used only sporadically since 1972, was dilapidated and in need of substantial repairs. Grou made no substantial repairs other than patching the roof. Grou initially planned to demolish the...