118 T.C. No. 32
UNITED STATES TAX COURT
CHARLES H. ADDIS AND CINDI ADDIS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6628-00. Filed June 10, 2002.
Ps claimed charitable contribution deductions for
their payments to NHF of $36,285 in 1997 and $36,000 in
1998. NHF, in turn, paid those amounts as premiums on
a so-called charitable split-dollar life insurance
policy on the life of P-W. NHF was entitled to receive
56 percent and Ps’ family trust was entitled to receive
44 percent of the death benefit provided by the policy.
NHF was not required to pay the premiums for that
policy. However, Ps reasonably expected NHF to do so
because Ps’ continued payments to NHF, and NHF’s
receipt of a death benefit, depended on NHF’s paying
the premiums.
NHF provided Ps with receipts for their payments
which stated that NHF did not provide any goods or
services to Ps in return for the payments. Ps claimed
charitable contribution deductions for the entire
amount of their payments to NHF.
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