T.C. Memo. 2004-271 UNITED STATES TAX COURT DAVID C. ROARK and ESTATE OF IRENE ROARK, DECEASED, DAVID C. ROARK, EXECUTOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 9231-02, 5105-03. Filed November 29, 2004. Earl S. Howell and Timothy R. Simonds, for petitioners. Edsel Ford Holman, Jr., for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION HOLMES, Judge: In 1998, David Roark gave $160,000 to a charity, the National Community Foundation (“NCF”). NCF sent him letters in return saying that “no goods or services have been provided in connection with this gift,” and he took his contributions as a deduction. But NCF used the money to pay the premiums on a $2.2 million insurance policy on Roark’s life thatPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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