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2. NHF
NHF is a section 501(c)(3) organization and is eligible to
receive tax-deductible contributions under section 170(c)(2).
3. The Addis Family Foundation
On October 10, 1997, petitioners established a fund within
NHF called the Addis family foundation. The purpose of the Addis
family foundation is to fund Christian organizations and programs
and individual evangelists. Mrs. Addis paid $285 to NHF to
establish the Addis family foundation.
4. The Life Insurance Policy on Mrs. Addis
On October 10, 1997, petitioner wrote to Dr. J.T. Houk, the
president of NHF, stating that the Addis family trust intended to
buy an insurance policy on the life of Mrs. Addis and would grant
NHF an option to acquire an interest in that policy.
On October 15, 1997, the Commercial Union Life Insurance Co.
of America (Commercial Union Life) issued a life insurance policy
on the life of Mrs. Addis (the life insurance policy or the
policy) to petitioner. Mrs. Addis was 44 years old at that time.
Petitioners owned the policy through the Addis family trust.2
The life insurance policy had a $40,000 annual premium and
an initial death benefit of $991,789.
2 Petitioners possess rights in the insurance policy solely
through the Addis family trust.
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