David C. Roark and Estate of Irene Roark, Deceased, David C. Roark, Executor - Page 1

                                 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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