Gary L. Weiner - Page 9

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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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