Gary L. Weiner - Page 8

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          the same conclusion here because the facts of this case and of              
          Addis are indistinguishable.                                                
               As in Addis, NHF gave petitioner receipts for his payments             
          which stated that NHF had not provided any goods or services to             
          petitioner in return for those payments.  Petitioner expected NHF           
          to use his payments of $93,000 to pay NHF’s portion of the                  
          premiums on the life insurance policies in 1997 and 1998 and thus           
          expected his family trusts to receive a substantial part of the             
          death benefits under the policies.  NHF failed to make a good               
          faith estimate of the value of those benefits as required by                
          section 170(f)(8)(B)(iii).                                                  
               Petitioner’s contention that his expectation that NHF would            
          pay the premiums on the life insurance policies was not                     
          consideration under section 170(f)(8) fails to take into account            
          the definition of consideration in section 1.170A-13(f)(6),                 
          Income Tax Regs.  A donee organization provides goods or services           
          in consideration for a taxpayer’s payment if, at the time the               
          taxpayer makes the payment to the donee organization, the                   
          taxpayer receives or expects to receive goods or services in                
          exchange for that payment.  Id.                                             
               Petitioner’s daughters, rather than petitioner, were the               
          trustees of the family trusts.  In contrast, in Addis, the                  
          taxpayers were the trustees.  Like the taxpayers in Addis,                  

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