David C. Roark and Estate of Irene Roark, Deceased, David C. Roark, Executor - Page 8

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          in an NCF form identifying himself as “charitable emissary,” and            
          reminding NCF of the details of the insurance policy’s deadlines            
          and mailing address for payment.                                            
               By late April 1998, then, all the parts of a charitable                
          split-dollar life insurance arrangement were assembled and in               
          place.  The policy was purchased, the Trust formed, the                     
          Foundation created, the Plan Agreement signed, and even an                  
          emissary appointed.  Roark began sending in his contributions.              
               Everything went smoothly at first.  By November 1998, Roark            
          had contributed a total of $160,000.  After each payment, NCF               
          sent a letter to him acknowledging his contribution.  Each was              
          signed by either NCF’s chief financial officer or one of its vice           
          presidents.  Each contained this language:                                  
               I further acknowledge that, New Life Corporation of                    
               America [NCF’s legal name] is a charitable organization                
               with the meaning of Section [170(c)] of the Internal                   
               Revenue Code, and is listed as such in the current                     
               revision of IRS Publication 78.  In accordance with IRS                
               regulations, no goods or services have been provided in                
               connection with this gift.                                             
               NCF used the money to pay $158,000 to IDS Life for premiums            
          on the policy in 1998 (keeping $2,000 in administrative fees),              
          with the first $48,000 on May 15, and the remaining $110,000 on             
          December 2.  Roark then made one additional contribution of                 
          $20,000 on December 23, 1998.  He again received a letter from              
          NCF acknowledging the contribution, and the letter again stated             
          that “no goods or services had been provided in connection with             






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