- 8 - 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 withPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011