Charles H. Addis and Cindi Addis - Page 13




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          C.   Whether NHF’s Receipts for Petitioners’ Payments Comply With           
               Section 170(f)(8) and Section 1.170A-13(f)(6), Income Tax              
               Regs.                                                                  
               Petitioners contend that NHF’s receipts comply with section            
          170(f)(8) and were contemporaneous written acknowledgments of               
          their contributions.  They further contend that the receipts were           
          accurate because they received no benefits in exchange for their            
          payments to NHF.  Petitioners’ contention fails to take into                
          account the definition of consideration in section 1.170A-                  
          13(f)(6), Income Tax Regs.  As stated above, under that                     
          regulation, a donee organization provides goods or services in              
          consideration for a taxpayer’s payment if, at the time the                  
          taxpayer makes the payment to the donee organization, the                   
          taxpayer receives or expects to receive goods or services in                
          exchange for that payment.                                                  
               NHF did not state in its receipts that NHF paid premiums for           
          the insurance policy on the life of Mrs. Addis under which                  
          petitioners would receive 44 percent of the death benefits.  NHF            
          failed to make a good faith estimate of the value of those                  
          benefits as required by section 170(f)(8)(B)(iii).                          
               The legislative history accompanying the enactment of                  
          section 170(f)(8) states:  “Organizations * * * [that provide               
          goods or services in consideration for payments from donors]                
          often do not inform their donors that all or a portion of the               
          amount paid by the donor may not be deductible as a charitable              






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