Addis v. Comm'r
United States Tax Court
Ps claimed charitable contribution deductions for their payments to NHF of $ 36,285 in 1997 and $ 36,000 in 1998. NHF, in turn, paid those amounts as premiums on a so-called charitable split-dollar life insurance policy on the life of P-W. NHF was entitled to receive 56 percent and Ps' family trust was entitled to receive 44 percent of the death benefit provided by the policy. NHF was not required to pay the premiums for that policy.
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Ps claimed charitable contribution deductions for their payments to NHF of $ 36,285 in 1997 and $ 36,000 in 1998. NHF, in turn, paid those amounts as premiums on a so-called charitable split-dollar life insurance policy on the life of P-W. NHF was entitled to receive 56 percent and Ps' family trust was entitled to receive 44 percent of the death benefit provided by the policy. NHF was not required to pay the premiums for that policy. However, Ps reasonably expected NHF to do so because Ps' continued payments to NHF, and NHF's receipt of a death benefit, depended on NHF's paying the premiums.…
1Opinion of the Court
Colvin, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax of $13,062 for 1997 and $12,960 for 1998.
Petitioners claimed charitable contribution deductions for their payment to the National Heritage Foundation (NHF) of $36,285 in 1997 and $36,000 in 1998, which NHF used to pay premiums on a life insurance policy for the life of petitioner Cindi Addis (Mrs. Addis). The insurance policy for Mrs. Addis was a so-called charitable split-dollar life insurance contract, under which NHF was entitled to receive 56 percent of the death benefit and petitioners’ family trust was…
2Cases cited2 opinions
- Hernandez v. CommissionerSupreme Court of the United States · 1989
- United States v. American Bar EndowmentSupreme Court of the United States · 1986
3Cited by27 opinions
- Charles H. Addis Cindi Addis v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2004
- Kaufman v. CommissionerUnited States Tax Court · 2011
- Van Dusen v. CommissionerUnited States Tax Court · 2011
- Gundanna v. Comm'rUnited States Tax Court · 2011
- Dunlap v. Comm'rUnited States Tax Court · 2012
22 more not listed; retrieve them via the Exa API.