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 that
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