Gary L. Weiner - Page 3

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          B.   Petitioner’s Family Trusts and Foundation                              
               1.   The Traci Rae Pontello Irrevocable Trust and the Frank            
                    James Pontello Irrevocable Trust                                  
               On September 21, 1995, petitioner created the Traci Rae                
          Pontello Irrevocable Trust (TRP trust) and the Frank James                  
          Pontello Irrevocable Trust (FJP trust).  Wendi Lyn Iannaccone was           
          trustee for the TRP trust, and Traci Rae Pontello was trustee for           
          the FJP trust.  Petitioner was the sole beneficiary of the TRP              
          and FJP trusts (the family trusts).  Under the trust instruments,           
          petitioner’s daughters become beneficiaries of the family trusts            
          upon the death of petitioner.                                               
               2.   NHF                                                               
               NHF is a section 501(c)(3) organization and is eligible to             
          receive tax-deductible contributions under section 170(c)(2).               
               3.   The Gary Weiner Family Foundation                                 
               On October 1, 1995, petitioner established a fund within NHF           
          called the Gary Weiner family foundation.  The purpose of the               
          Gary Weiner family foundation is to fund medical research and               
          other educational programs.  Petitioner paid $265 to NHF to                 
          establish his foundation.                                                   
          C.   The Charitable Split-Dollar Insurance Agreements                       
               On October 15, 1995, the family trusts and NHF entered into            
          split-dollar insurance agreements (SDIAs) to divide the death               
          benefits from the life insurance policies on the lives of Traci             

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