Charles H. Addis Cindi Addis v. Commissioner of Internal Revenue
Opinion
Opinion
Noonan, J.
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 the deductions and affirm the decision of the Tax Court.
FACTS
Charles Addis is a farm labor contractor and his wife Cindi Addis is a bookkeeper. They are the initial trustees and beneficiaries of the Charles H. Addis Family Trust, which they created on May 7, 1986. On the couple’s deaths, the trust benefits their family members.
The NHF is a tax-exempt organization under 26 U.S.C. § 501 (c)(3) and is eligible to receive tax-deductible contributions under 26 U.S.C. § 170 if tax code requirements are satisfied.
The questions we consider arise from the Addises’ attempts to claim charitable contribution…