- 14 - Perhaps anticipating this, Roark tries to distinguish his case from Addis’s by stating--correctly--that Addis admitted that she expected the charity in her case to pay the premiums. Addis 118 T.C. at 535. Roark, in contrast, testified that he had no idea what was going on with NCF and the charitable split-dollar life insurance plan, and that every time he got information about it, he simply turned it all over to Pippenger. We do not find this disavowal credible. The idea for this deal, after all, came from Pippenger--his financial, not his charitable, adviser. Roark had to have realized that the intricacy of the plan, plus the fact that it was being marketed so extensively by American Express, suggested that as a practical matter NCF would of course use money it got under such plans to pay for insurance and not just add to its endowment. Failure to do so would have been a massive denial of its donors’ expectations, as NCF itself recognized when it let loose with its letterwriting surge after Congress began considering the excise tax on premiums. We also find that NCF’s payment of the premiums was something of value to Roark. Of the policy’s $2.2 million death benefit, a maximum of only $489,000 would go to NCF. The Trust, which was set up by Roark and whose beneficiaries were his wife and children, would receive the other $1.711 million. The Trust would thus take 78 percent of the total death benefit, while NCFPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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