- 6 - 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’ fundsPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011