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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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