Charles H. Addis and Cindi Addis - Page 8




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          extent that the policy’s cash surrender value5 exceeded the                 
          termination account value.  The policy’s cash surrender value did           
          not exceed its termination account value during the years in                
          issue.                                                                      
               Under the DBOA, as long as the annual premium of $40,000 was           
          paid, the Addis family trust was entitled to receive a death                
          benefit of $434,509 plus any increase in the death benefit from             
          the initial death benefit of $991,789.                                      
               Under the DBOA, the Addis family trust was required to pay             
          the premiums on the policy if the cumulative premiums were                  
          inadequate to fund NHF’s cost of insurance.                                 
               8.   Enactment of Section 170(f)(10) in 1999                           
               Petitioners stopped making payments to NHF after 1998.  NHF            
          no longer participates in charitable split-dollar life insurance            
          arrangements because of the enactment in 1999 of section                    
          170(f)(10),6 which requires charities to pay a 100-percent excise           
          tax on certain life insurance premium payments.                             





               5  A policy’s cash surrender value is its total gross cash             
          value less any surrender charges imposed by the insurer on the              
          surrender of the policy.                                                    
               6  Sec. 170(f)(10) was added to the Code by sec. 537(a) of             
          the Ticket to Work and Work Incentives Improvement Act of 1999,             
          Pub. L. 106-170, 113 Stat. 1860, 1936, generally effective for              
          transfers after Feb. 8, 1999.                                               






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