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life insurance policies for the lives of petitioner’s daughter
and son-in-law. The insurance policies were so-called charitable
split-dollar life insurance contracts, under which NHF was
entitled to receive from 48 percent to 92 percent of the initial
death benefits, and petitioner’s family trusts were entitled to
receive from 8 percent to 52 percent of those benefits.
Respondent determined that petitioner is not entitled to
charitable contribution deductions for his payments to NHF.
The sole issue for decision is whether petitioner may deduct
his payments to NHF as charitable contributions.1 We hold that
he may not.
Unless otherwise indicated, section references are to the
Internal Revenue Code.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioner
Petitioner, a dentist, resided in Los Angeles, California,
when he filed the petition. Traci Rae Pontello and Wendi Lyn
Iannaccone are petitioner’s adult daughters, and Frank James
Pontello is petitioner’s son-in-law.
1 Petitioner contends that sec. 7491(a) requires respondent
to bear the burden of proof on all issues in the case. We need
not decide petitioner’s contention because our findings and
analysis do not depend on which party bears the burden of proof.
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