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petitioner expected that he would benefit from his payments to
NHF. Just as in Addis, NHF used petitioner’s money to pay the
premiums on the life insurance policies under which petitioner or
his daughters, through the family trusts, were entitled to
receive a substantial part of the death benefits.
As in Addis, petitioner’s failure to comply with section
170(f)(8) results in disallowance of his charitable contribution
deductions. Thus, petitioner may not deduct his contributions to
NHF of $93,000 in 1997 and $93,000 in 1998.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011