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Held: No part of Ps’ payments to NHF is
deductible as a charitable contribution to NHF because
Ps did not meet the substantiation requirements of sec.
170(f)(8), I.R.C., and sec. 1.170A-13(f)(6), Income Tax
Regs.
Steven Toscher and Michel R. Stein, for petitioners.
Lorraine Wu, for respondent.
COLVIN, Judge: Respondent determined deficiencies in
petitioners’ Federal income tax of $13,062 for 1997 and $12,960
for 1998.
Petitioners claimed charitable contribution deductions for
their payment to the National Heritage Foundation (NHF) of
$36,285 in 1997 and $36,000 in 1998, which NHF used to pay
premiums on a life insurance policy for the life of petitioner
Cindi Addis (Mrs. Addis). The insurance policy for Mrs. Addis
was a so-called charitable split-dollar life insurance contract,
under which NHF was entitled to receive 56 percent of the death
benefit and petitioners’ family trust was entitled to receive 44
percent. Respondent disallowed petitioners’ charitable
contribution deductions for all of their payments to NHF.
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Last modified: May 25, 2011