This is correct— the IRS can easily rule on this, without even a court test case-—
The payoff of a student owned debt by another is IMPUTED income, which is taxable.
And, it is completely suspect that the billionaire can “tax write off “ the payment of another’s debt. It just isn’t so. This is politically contrived nonsense.
IRS already ruled kids will pay no taxes.
Even I can figure this one out: You pay your highly connected lawyer to set up a 501-C3 charity whose purpose is to pay the student loans of "under privileged minority" students. The charity hires your grandchild to 'administer' the charity for a couple hundred grand a year. Then donate to the charity. You get to write off everything, including the payment to your grandchild (or grandchildren).