Legal Opinion
Charles H. Addis Cindi Addis v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided July 8, 2004No. 02-73628PublishedCited by 27 opinions
1Opinion of the Court
NOONAN, Circuit Judge.
Charles H. Addis and his wife Cindi Addis appeal a Tax Court judgment denying them charitable contribution deductions for their payments to the National Heritage Foundation (“NHF”) in 1997 and 1998. The central question is whether 26 U.S.C. § 170(f)(8) disallows the deductions because the receipts substantiating the transfers to the NHF stated the Addises received no consideration though they expected the NHF to use their funds to pay part of the premiums on life insurance benefiting their trust pursuant to a split-dollar arrangement. We hold that section 170(f)(8) bars…
2Cases cited3 opinions
- United States v. BiscegliaSupreme Court of the United States · 1975
- Bromley v. McCaughnSupreme Court of the United States · 1929
- Addis v. Comm'rUnited States Tax Court · 2002
3Cited by27 opinions
- 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
- Irby v. Comm'rUnited States Tax Court · 2012
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