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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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Last modified: May 25, 2011