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NHF gave petitioner a receipt for each of his $93,000
payments in which NHF stated that “NHF did not provide any goods
or services to the donor in return for the contribution.”
F. Petitioner’s Tax Returns and the Notice of Deficiency
Petitioner claimed deductions for charitable contributions
to NHF of $93,000 in 1997 and $93,000 in 1998. Respondent
determined in the notice of deficiency that petitioner is not
entitled to those deductions.
OPINION
Petitioner contends that he may deduct $93,000 in 1997 and
1998 as charitable contributions to NHF. We disagree.
We recently decided Addis v. Commissioner, 118 T.C.
(2002), in which the taxpayers deducted their payments to NHF
under a split-dollar life insurance plan. The split-dollar life
insurance plan in Addis is indistinguishable from the plan that
petitioner used. In Addis, NHF used the funds from the taxpayers
to pay for life insurance on the life of Mrs. Addis and, as a
result, the taxpayers’ family trust became entitled to receive
part of the death benefits from the life insurance policy. In
Addis, NHF gave the taxpayers receipts in which NHF stated that
the taxpayers received no consideration in exchange for their
payments. We held that the taxpayers could not deduct the
payments as charitable contributions because NHF did not state in
the receipts for those payments that it used the taxpayers’ funds
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Last modified: May 25, 2011