- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011