Means that the payoff for each student is taxable income for 2019, due in 2020.
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.