Charles H. Addis and Cindi Addis - Page 1

                                   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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