David C. Roark and Estate of Irene Roark, Deceased, David C. Roark, Executor - Page 4

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               NCF, the third major player in this case, is a section                 
          501(c)(3) charitable organization based in Brentwood, Tennessee.            
          It receives money from both its own investments and donations.              
          One of the ways it receives donations is through “donor-advised             
          accounts,” also known as “individual foundations.”  Donors to               
          these foundations contribute money or other property to a special           
          individual account, and they can direct NCF to contribute up to             
          75 percent of the principal and interest from that account to               
          other charities of their own choosing.  The remaining 25 percent            
          of each account goes to the charitable programs of NCF, which               
          focus on Christian evangelical and humanitarian services.                   
               Pippenger first became aware of charitable split-dollar life           
          insurance plans in 1997.  A conscientious investment adviser, he            
          studied the arrangement by attending, at his own expense,                   
          seminars put on by American Express; he also performed his own              
          due diligence independently.  He came to see these plans as an              
          opportunity to benefit his clients who were interested in estate            
          planning: since proceeds of a life insurance contract that are              
          paid by reason of the insured’s death are excluded from income,             
          sec. 101(a)(1), sharing the cost of the premiums with a charity             
          in a way that created current tax deductions would obviously be             
          attractive.  Sometime in early 1998 Pippenger met with the Roarks           
          to discuss the value of Mr. Roark’s business, and the potential             
          taxes that his estate would face upon his death.  Pippenger told            






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