FUNDING CHARITABLE GIFTS

Using Life Insurance to Fund a Donor's Charitable Gifts

Life insurance can be an effective funding vehicle for charitable gifts. This article explores such strategies as naming a charity as beneficiary of an insurance policy, giving a policy to charity, and using insurance with CRTs.

Author: KEVIN D. MILLARD, Attorney

KEVIN O. MILLARD, of the Minnesota and Colorado Bars, is a shareholder in the law firm of Millard & Hunter, P.C., in Englewood, CO. He is also Vice-Chair of the Insurance Committee of the ABA's Real Property, Probate and Trust Law Section. Mr. Millard has written and lectured extensively on estate planning.

Life insurance is often an important component of an estate plan. Estate planners are generally familiar with using life insurance, for example, to create an estate in the event of the insured's early death, to provide income to a surviving spouse, or to generate liquidity for the payment of estate taxes and other death costs. This article examines the use of life insurance for funding a donor's charitable gifts.

Charitable deductions

The tax law encourages philanthropy through income, gift, and estate tax deductions for qualifying charitable gifts. An income tax deduction is allowed for charitable contributions to or for the use of organizations described in Section 170(c) . 1 In addition, a gift or estate tax deduction is allowed if the charity is one specified in Section 2522(a) or 2055(a) . If the contribution consists of property, rather than cash, the contribution typically equals the fair market value of the property when contributed. 2 In determining the amount of the contribution that is deductible for income tax (but not gift or estate tax) purposes, the value of the property is reduced by the gain that would not have been long-term capital gain if the donor had sold the property for its FMV at the time of the contribution. 3

The income tax deduction is also subject to several “percentage limitations.” Generally, contributions are deductible only up to 50% or 30% of the donor's “contribution base” for the taxable year, depending on whether the donee charity is or is not described in Section 170(b)(1)(A) . 4 (The contribution base is the donor's adjusted gross income for the taxable year of the contribution, computed without regard to any net operating loss carryback to that year.) Contributions “for the use of,” rather than “to,” a charitable organization are subject to the 30% limitation, even if the donee charity is an organization specified in Section 170(b)(1)(A) . Excess contributions subject to either the 50% or the 30% limitation may be carried forward for up to five years. 5 No percentage limitations apply to the gift and estate tax charitable deductions.

A charitable deduction is allowable for a contribution in trust that has both charitable and noncharitable beneficiaries only if the trust qualifies as a charitable remainder annuity trust, a charitable remainder unitrust, a pooled income fund, or a charitable lead trust that provides either a guaranteed annuity or unitrust interest to charity. 6 Furthermore, for purposes of the income tax charitable deduction, a charitable lead trust must be a grantor charitable lead trust. If a donor makes a contribution not in trust of less than his entire interest in the property, an income tax charitable deduction is allowed only if (1) the contribution would have been deductible if made in trust or (2) the contribution consists of a remainder interest in a personal residence or farm, an undivided portion of the taxpayer's entire interest in the property, or a qualified conservation easement. 7 A gift or estate tax charitable deduction is permitted for contributions described in #2 above. 8 If a contribution is subject to a condition that might prevent the gift from becoming effective, no deduction is allowable unless the possibility that the charitable transfer will not become effective is so remote as to be negligible. 9

In the case of a testamentary gift, the possibility that the gift might be defeated or reduced by the exercise of the surviving spouse's or an heir's right to a forced share does not preclude a charitable estate tax deduction, so long as the gift to charity is thereby made only voidable, not void, and the right to a forced share is not, in fact, exercised. 10 If any death taxes are payable out of, or charged against, a gift to charity pursuant to the estate plan or under applicable law, the charitable deduction is reduced by those taxes. 11

An outright gift to a charity ordinarily does not give rise to any generation-skipping transfer tax, because charitable organizations are generally assigned to the transferor's generation. 12 Thus, most charitable gifts do not result in any generation- skipping transfer, although such transfers may occur under trusts with noncharitable as well as charitable beneficiaries if the noncharitable beneficiaries include skip persons.

Naming a charity as beneficiary of a policy

The simplest form of charitable gift funded with life insurance is the designation, by the insured-owner of the policy, of a charity as the beneficiary of the policy. No income tax deduction is allowed because the donor does not part with control over the policy during life. 13 If, however, the insurance is employer-provided group term insurance under Section 79 , the usual rule that the employee must include in income the cost of coverage in excess of $50,000 does not apply if a charity described in Section 170(c) is named as sole beneficiary for the entire period during the year for which the coverage is provided. 14 Designating a charity as beneficiary of a policy may allow a donor to make a larger gift than he could otherwise afford, yet without giving up access to the cash value of the policy during the insured's lifetime. At the insured's death, the policy proceeds are includable in his gross estate, 15 but there should be an offsetting estate tax charitable deduction. The donor's estate plan should specifically provide that all death taxes will be paid from a source other than the charitable gift, to negate the right of recovery under Section 2206 for death taxes “attributable” to life insurance payable to a beneficiary other than the estate.

While the charitable deduction can eliminate any estate tax on the life insurance death benefit, the inclusion of the death proceeds in the insured's gross estate can have a collateral effect on the estate's qualification for tax provisions that depend on the size of the estate, such as a redemption of stock to pay death taxes and funeral and administration expenses under Section 303 , or an election under Section 6166 to pay in installments death taxes attributable to an interest in a closely held business. Moreover, depending on applicable state law, a spouse or heir might be able to disrupt the donor's charitable gift by exercising a right to a forced share of the decedent's estate. For example, the Uniform Probate Code includes in the “augmented” estate (from which the surviving spouse may take a forced share) life insurance owned by the decedent and payable other than to the surviving spouse. 16

Gift of a policy to charity

Instead of simply naming a charity as beneficiary of a life insurance policy, the donor may want to transfer ownership of a policy on his life to a charitable organization, or make cash gifts to the charity with the understanding that the charity will use the funds to purchase insurance on the donor's life. Subject to the insurable interest problem discussed below, such a gift, if properly planned, can generate a current income tax deduction and avoid transfer taxation because of the gift and estate tax charitable deductions.

Insurable interest. Every state requires, at the inception of the contract, the existence of an insurable interest between the applicant-owner of an insurance policy and the prospective insured. 17 Underlying this rule is the public policy against wagering contracts. Some older authority held that a charitable organization did not have an insurable interest in the life of a voluntary contributor. 18

That changed during the 1900s, however, and it became an acceptable practice for donors to encourage charities and other nonprofit institutions to apply for life insurance on their lives, with the donors providing a means of paying the premiums, often using trusts. It was widely believed that the various state statutes regarding insurable interest included the relationship between a charity or nonprofit organization and its donors. 19

Ltr. Rul. 9110016 called into question this “acceptable practice.” (Although a private letter ruling may not be used or cited as precedent, such a ruling may provide a useful indication of the Service's thinking on a particular issue.)

The facts of Ltr. Rul. 9110016 were simple. A, an independent contractor of, and past contributor to, a charity, proposed to apply for an insurance policy on her life, naming the charity as sole beneficiary. Upon receipt of the policy, A planned to assign it to the charity. A also intended to pay the future premiums on the policy. Unfortunately, A conceded that the charity did not have an insurable interest in her life under applicable state (New York) law. That was the stated reason why A would initially apply for the policy and then transfer it to the charity.

The IRS ruled that A would be entitled to neither an income tax nor a gift tax charitable deduction for the gift of the policy and subsequent premium payments. When an insured dies, if the insurer discovers that the requisite insurable interest was lacking, the insurer is not required to pay the death benefit. 20 If the insurer carries out the contract and pays the death benefit to the beneficiary, notwithstanding the lack of insurable interest, the insured's estate may be entitled to recover the death benefit from the beneficiary.

Because of the possibility that the insurer might not have to pay the benefit, or if it did, that the personal representative of A's estate might sue to recover the proceeds, the IRS concluded that when A assigned the policy to the charity, she would be transferring a partial interest in the policy, which was less than her entire interest. The IRS also determined that the possibility that the charity would be divested of its interest was not so remote as to be negligible.

According to the Service, the policy death benefit would be includable in A's estate regardless of when A died: either under Section 2035(a) if A died within three years or under Section 2033 if A lived for more than three years because of A's estate's right of recovery under the insurable interest statute. In either event, A's estate would not be entitled to an estate tax charitable deduction, because if the death benefit, in fact, passed to charity and was not challenged by the insurer or A's personal representative, the proceeds would not pass from A but, in effect, from A's heirs or devisees as a result of A's personal representative not seeking to recover the proceeds.

Ltr. Rul. 9110016 was revoked by the IRS not long after its issuance. 21 Prior to its revocation, however, the ruling received a great deal of publicity and led to the adoption of a number of state statutes expressly intended to provide that a charity has an insurable interest in a donor, or to allow a donor, as proposed in the ruling, to obtain a life insurance policy and then immediately transfer it to charity. 22

Insurable interest is a matter of state law, and practitioners should review the applicable law before advising a client to make a charitable gift of an insurance policy. Furthermore, it has been suggested that another problem might exist if the insured dies within three years even if, under state law, the charity has an insurable interest in the donor. If the insured obtains the policy, transfers it to the charity, and then dies within three years, the death proceeds are includable in the insured's estate under Section 2035(a) . Under Section 2206 , the personal representative has a right of reimbursement for estate tax caused by that inclusion “[u]nless the decedent directs otherwise in his will.” Thus, if state law gives a charity an insurable interest in its donor, it may be advisable for the charity to be the initial applicant for, and owner of, the policy. 23 At a minimum, the estate plan should expressly provide that no death taxes will be paid out of, or charged against, property qualifying for the charitable deduction.

The problem in Ltr. Rul. 9110016 ought not arise in the case of an assignment to charity of an existing policy that was not obtained with the intent that it immediately be given to charity. Normally, if there is no intent to transfer the policy, no question of insurable interest arises when the proposed insured is also the applicant and owner of the policy. 24 One who lacks an insurable interest may not evade the law by arranging for the insured to apply initially for the policy and then immediately assign the policy. On the other hand, if a policy was procured by the insured in good faith, most courts hold that the insured may thereafter assign the policy to an assignee who does not have an insurable interest. 25

Available deductions

Income tax deduction. Assuming that the insurable interest problem discussed above can be avoided, a gift of a life insurance policy to a qualified charity results in an income tax charitable deduction. If the donor pays subsequent premiums on the policy, these payments constitute additional gifts, resulting in additional income tax deductions when made. 26 Premium payments directly from the donor to the insurer are likely to be considered contributions “for the use of” the charity, subject to the 30% limitation. 27 Therefore, it may be advisable for the donor to make cash gifts to the charity sufficient to allow the charity to pay the premiums.

To avoid disallowance of a deduction under the partial interest rule, the gift either must consist of the donor's entire interest in the policy or must be an undivided interest in the policy. Consequently, there is no charitable income tax deduction for a gift to charity of an interest in a life insurance policy under a split-dollar arrangement. 28 Nevertheless, the IRS, in private rulings, has approved deductions for gifts of life insurance where the donor retained the right, in conjunction with the donee charity, to substitute or add charitable beneficiaries, 29 and where the donor gave the charity a nonbinding “Letter of Intent,” which he might change from time to time, indicating the donor's preferences as to the distributions to be made by the charity. 30

If an existing policy is given to charity, the contribution equals the FMV of the policy at the time of the contribution. It appears that the value of a life insurance policy for purposes of the income tax charitable deduction is generally the same as its value for gift tax purposes. 31 Under the gift tax Regulations, the FMV of a policy is usually its replacement cost. 32 Hence, the value of a newly issued policy is equal to the initial premium paid, 33 and the value of a paid-up policy is the amount that the insurer would charge for a single premium contract of the same specified amount on the life of a person the age of the insured. 34 In the case of a policy that has been in force for some time and on which further premiums are to be paid, the replacement cost is approximated by the interpolated terminal reserve plus the unearned premium.

In Ltr. Rul. 8943014 , the IRS was asked to rule that the FMV of a life insurance policy that was issued on 7/28/88 and contributed to a private foundation on 12/12/88 equalled the interpolated terminal reserve plus the unearned premium on the date of the gift. The Service refused to rule on that point due to the Service's policy of not providing rulings on valuation issues. The Service pointed out, however, that the valuation method based on the interpolated terminal reserve plus unearned premium applies to policies that “have been in force for some time.” Because the policy in the ruling was contributed to charity less than five months after its issue date, it was not possible to say that that was the correct method for valuing the policy. It is somewhat curious that the taxpayer requested a ruling that the value was the interpolated terminal reserve plus unearned premium, because the cost of the policy would likely have been a higher number, resulting in a larger deduction.

There is some authority that the replacement cost method of valuation for gift tax purposes does not always apply in valuing a policy for purposes of the income tax charitable deduction. In Tuttle 35 the taxpayers' son, who was an insurance agent, donated a $50,000 policy on his own life to a church. The policy was “paid-up,” but was subject to a large loan that reduced its net cash surrender value to less than $1,000. Three weeks after the donation, the insured's parents purchased the policy from the church for $1,000, and about six months later they donated it to a community foundation, which surrendered the policy. The Second Circuit concluded that it was reasonably predictable that the foundation would surrender the policy and held that the appropriate measure of the value of the policy for purposes of the income tax charitable deduction was the cash surrender value, rather than the replacement value.

The donor's income tax deduction must be reduced by any gain that would not have been long-term capital gain if the donor had sold the policy for its FMV at the time of the contribution. Gain from the sale of a life insurance policy is taxable as ordinary income. 36 Therefore, the income tax charitable deduction for a gift of an insurance policy is effectively the lesser of the FMV of the policy or the donor's basis in the policy.

Under Section 72(e)(4)(C) , a gift of an annuity policy issued after 4/22/87 causes the donor to recognize any gain inherent in the contract. But because that gain is actually recognized, there is no reduction in the charitable gift under Section 170(e)(1)(A) , 37 and the full value of the policy is deductible. In the case of a charitable gift of a matured annuity contract issued before 4/23/87, the donor must recognize as income the excess of the contract's maturity value over his investment in the contract. Because that income is recognized (as in the case of a post-4/22/87 annuity), there is no reduction in the income tax charitable deduction under Section 170(e)(1)(A) , and the full maturity value of the contract is deductible. A donor who makes a charitable gift of an unmatured annuity contract issued before 4/23/87 must include in income the gain existing at the time of the gift, but the income is not includable until the year in which the contract is surrendered by the donee. 38 Consequently, the charitable contribution deduction must be reduced under Section 170(e)(1)(A) .

A charitable gift of a life insurance policy is subject to the substantiation rules for charitable deductions. Accordingly, if the deduction exceeds $5,000, a “qualified appraisal” is required, and an “appraisal summary” must be attached to the return on which the deduction is first claimed. 39 This seems a silly requirement for a gift of a life insurance policy the value of which, as a practical matter, is often taken from an IRS Form 712 prepared and furnished by the insurance company. Nevertheless, there is no exception to the qualified appraisal requirement for a gift of an insurance policy.

All contributions of $250 or more must be substantiated by a written acknowledgement from the donee charity. 40 If a donor makes direct premium payments on a policy owned by a charity, the charity may not be in a position to verify receipt of the gift, and the donor may lose the income tax deduction because of inability to obtain written verification from the charity. Hence, this is another reason why it is preferable for the donor to give the charity sufficient cash gifts to allow the charity to pay the premiums.

Gift and estate tax deductions. If a donor transfers a life insurance policy to a qualifying charity, the gift is deductible for gift tax purposes under Section 2522(a) . If the donor pays subsequent premiums due on the policy, those premium payments constitute additional gifts 41 that also qualify for the gift tax charitable deduction. The gift equals the premium, not the increase in the value of the policy resulting from the gift. The partial interest rule precludes any gift tax deduction for a gift to charity under a split-dollar life insurance arrangement. 42

If a donor transfers a life insurance policy to a charity and lives more than three years after the transfer, the policy proceeds are not included in the donor's estate. The proceeds should also be excluded from the estate if the donor makes a cash gift to a charity and cooperates in the purchase of an insurance policy on his life, so long as the charity is the applicant for, and initial owner of, the policy. 43 If the insured owns a policy, transfers it to a charity, and then dies within three years, the policy proceeds are included in the insured's gross estate under Section 2035(d)(2) . In that event, though, there is an offsetting estate tax charitable deduction under Section 2055(a) .

Effect on charity

In most cases, the gift of a life insurance policy to a charitable organization has no adverse tax consequences to the charity. If, however, the charity is a private foundation and the gift policy is subject to an outstanding loan, or if the charity borrows against the policy, several issues arise.

A gift of a life insurance policy to a private foundation is not a jeopardy investment, because an investment made by a donor which is later gratuitously transferred to the foundation is not subject to the tax on jeopardy investments. 44 But the IRS has ruled that a foundation's retaining (rather than surrendering) a life insurance policy subject to a loan was a jeopardy investment when the combined premiums and interest payments on the policy would be greater than the expected return to the foundation from the death benefit if the insured lived to life expectancy. 45

Under Section 4941(d)(2)(A) , a transfer of property by a disqualified person to a private foundation is treated as a sale or exchange of the property, and thus an act of self-dealing, if the foundation takes the property subject to a mortgage or similar lien that the disqualified person placed on the property within the ten-year period ending on the date of the transfer. As a result, a gift of an encumbered life insurance policy to a private foundation is an act of self-dealing if the donor is a disqualified person and the loan was made within the ten-year period ending on the date of the gift. Even though a loan against a life insurance policy is not a personal obligation of the policy owner, the transfer of the policy subject to the loan relieves the donor of the obligation to repay the loan, to pay interest on the loan, or to suffer continued diminution in the value of the policy as the loan interest is charged against the cash value. 46

An otherwise income tax exempt charity is subject to tax on its unrelated business taxable income (UBTI) pursuant to Section 511(a) . Because UBTI includes income from “debt-financed property,” 47 policy loans can result in UBTI. In Mose & Garrison Siskin Memorial Foundation 48 a foundation borrowed the cash values of life insurance policies that had been donated to it and reinvested the proceeds in marketable securities. Although the loans resulted in interest charges of about 5.5% per year, the foundation earned more than 10% yearly on the investments it made with the loan proceeds.

The foundation argued that its withdrawals from the policies were not “indebtedness” for purposes of the debt-financed property rules, because (1) a loan against a life insurance policy is not a true loan, but simply an advance against funds that the insurer will eventually pay, (2) those advances did not create a true debtor-creditor relationship because the foundation was not obligated to repay the loans, and (3) the “interest” charged by the insurers was not really interest but “charges” for maintaining the face values of the policies. The Sixth Circuit acknowledged that a life insurance policy loan is different from an ordinary loan. Nevertheless, the court pointed out that policy loans have been treated as “indebtedness” under the rules allowing or disallowing an income tax deduction for interest on life insurance policy loans. 49 Therefore, the court held that the foundation's policy loans were acquisition indebtedness and that the income earned by the investment of the loan proceeds was debt-financed income, resulting in UBTI to the foundation. Even after paying tax on its UBTI, the foundation did well economically because of the much greater return it earned on the borrowed funds. As discussed below, the consequences of UBTI are more severe for a charitable remainder trust (CRT).

Use of life insurance with CRTs

The IRS has ruled privately that a CRT may be funded with a life insurance policy. 50 Subsequent premium payments by the donor are treated as additional contributions to the trust. Thus, only a charitable remainder unitrust (CRUT), and not a charitable remainder annuity trust (CRAT), is a candidate for funding with a life insurance policy for which additional premiums must be paid out of funds provided by the donor in the future, because additional contributions may be made to a CRUT but not to a CRAT. 51 In Ltr. Rul. 8745013 , the Service concluded that the purchase of a life insurance policy by a CRT is not automatically a jeopardy investment, but the ruling refers to Rev. Rul. 80-133 , 52 which holds that the retention of a life insurance policy may be a jeopardy investment, based on the facts and circumstances. In Ltr. Rul. 8745013 , the Service also determined that if the trustee borrowed against the policy and invested in other assets, the resulting income would be debt-financed income, which would give rise to UBTI. Unlike other tax-exempt organizations, a CRT is not taxable merely on UBTI. A CRT is exempt from income tax for a taxable year only if it does not have UBTI for that year. 53 Accordingly, even a nominal amount of debt-financed income could cause a CRT to be taxed on all its income for the year.

A trust does not qualify as a CRT unless and until neither the grantor nor any other person is treated as the owner of the trust for income tax purposes under the grantor trust rules. 54 (For this purpose, however, neither the grantor nor his spouse is treated as the owner of the trust merely because he or she is a beneficiary of the trust.) In Ltr. Rul. 9227017 , the donor proposed to transfer a policy on his own life, as well as other assets, to a trust designed as a CRT. The trust was a net income unitrust with a make-up provision. 55 The unitrust amount was the lesser of the trust income determined under Section 643(b) or 5 % of the net FMV of the trust assets, valued annually. The trustee was also to distribute income for a year in excess of the 5% limit to the extent that, in prior years, the aggregate distributions were less than they would have been if the payout had been determined without regard to the trust income.

The power of a trustee, without the consent of any adverse party, to use trust income to pay premiums for insurance on the life of the grantor normally causes the trust to be a grantor trust for income tax purposes. 56 This rule, however, does not apply to a policy irrevocably payable for a charitable purpose specified in Section 170(c) . The trust agreement in Ltr. Rul. 9227017 provided that all premiums for the life insurance policy would be charged to principal, not income, and that all policy proceeds received either during the insured's life or at death would be credited to trust principal. Based on these provisions, the Service ruled that the policy was irrevocably payable for a charitable purpose, and the trust was not a grantor trust under Section 677(a)(3) . The Service did not specifically rule that the trust qualified as a CRT. It is not clear from the ruling whether the taxpayer had asked for a ruling on qualification of the trust as a CRT or only for a ruling on the grantor trust issue.

In recent years, there has been considerable interest in the use of a deferred annuity contract as the funding vehicle for a net income CRUT with a make-up provision. When a commercial annuity contract is not held by a natural person, the usual rules for taxation of the income from the annuity do not apply. Instead, all income on the contract for a taxable year is treated as ordinary income received or accrued by the owner of the contract. 57 In the case of a net income type of CRUT, the annual payout is a fixed percentage of the value of the trust assets, valued annually, or the trust's net income, if less. For this purpose, “net income” means income determined under the governing instrument and local law. 58

If an annuity is held by a CRUT, the provisions of the trust relating to allocations between principal and income can be drafted to provide that income from the annuity contract will be considered trust accounting income only when actually received by the trustee. So long as this trust provision is not considered by the IRS to “depart fundamentally from concepts of local law,” it will be respected for federal tax purposes. 59 Assume the annuity is the only trust asset. The value of the contract builds up over time, but until the trustee annuitizes or makes withdrawals from the contract, the trust will have zero “income” to be distributed. At a future time, the trustee can make withdrawals from the contract and, because those withdrawals will be characterized as income at that time, they can be used to pay not only the current unitrust payments but also shortfalls from the prior years under the make-up provision.

Consequently, a CRUT funded with a deferred annuity contract can allow for substantial appreciation during the period in which no withdrawals are made, and a relatively certain source of income payments in the future for the donor or other noncharitable beneficiary when the trustee makes withdrawals from the annuity contract. The IRS has ruled privately that a purported CRUT that proposed to invest in a deferred annuity contract would qualify as a CRT. 60 Use of this technique requires careful drafting as well as close attention to state law relating to trust principal and income.

Conclusion

Life insurance can be an effective funding vehicle for charitable gifts as part of a client's estate plan. An estate planner whose client wishes to use life insurance or annuities for charitable gifts must become familiar with, and carefully analyze, the complex and technical rules relating to the charitable income, gift, and estate tax deductions as well as the tax rules applicable to charities and charitable trusts.


1

   Section 170(a) .


2

   Reg. 1.170A-(c)(1) ; Sections 2055(a) , 2055(d) , and 2522(a) .


3

   Section 170(e)(1) .


4

   Section 170(b)(1) .


5

   Sections 170(d) and 170(b)(1)(B) .


6

   Sections 170(f)(2) , 2055(e)(2) , and 2522(c)(2) .


7

   Section 170(f)(3) .


8

   Sections 2055(e)(2) and 2522(c)(2) .


9

   Regs. 1.170A- 1(e) Regs. 1.170A- 1(e) , 20.2055-2(b) , and 25.2522(c)-3(b) .


10

   Reg. 20.2055-2(e)(1)(i) , Example (6); Longue Vue Foundation, 90 TC 150 , acq. in result only.


11

   Section 2055(c) .


12

   Section 2651(e)(3) .


13

   Adler, 5 BTA 1063 .


14

   Section 79(b)(2)(B) .


15

   Section 2042(2) .


16

  Uniform Probate Code section 2-202(b)(2)(iii) (1990).


17

  Graves and Hayes, eds., McGill's Life Insurance (The American College, 1994), 774 (hereinafter “Graves and Hayes”).


18

   Trinity College v. Insurance Co., 113 N.C. 244 .


19

  Graves and Hayes, Note 17 supra , at 779-80.


20

  Id. at 785.


21

   Ltr. Rul. 9147040 .


22

  See, e.g., Colo. Rev. Stat. §10-7-115; Md. Ann. Code art 48A, §366; Minn. Stat. §61A.073; Ohio Rev. Code Ann. §§3911.09-.10; S.Dak. Codified Laws Ann. §58-10-4; Va. Code §38.2-301(B)(4); Wash. Rev. Code §48.18.030.


23

  2A Casner and Pennell, Estate Planning (5th ed. Supp. 1994), §§8.10.1.


24

  Anderson, Anderson on Life Insurance (1991), §12.3 (hereinafter “Anderson”); Graves and Hayes, Note 17 supra , at 779.


25

  Anderson, Note 24 supra , §12.11.


26

   Behrend, 23 BTA 1037 ; Hunton, 1 TC 821 ; Ltr. Ruls. 8304068 and 8708083 .


27

  Kirschten and Neeley, 281-3rd T.M. (BNA), Charitable Contributions: Income Tax Aspects, page A-10, n. 102; Zaritsky and Leimberg, Tax Planning With Life Insurance (Warren, Gorham & Lamont, 1992), ¶8.02[1][b] .


28

   Rev. Rul. 76-143, 1976-1 CB 63 .


29

   Ltr. Rul. 8030043 .


30

   Ltr. Rul. 8714037 .


31

   Rev. Rul. 59-195, 1959-1 CB 18 .


32

   Reg. 25.2512-6(a) .


33

   Rev. Rul. 58-372, 1958-2 CB 99 ; Reg. 25.2512-6(a), Example (1) .


34

   Reg. 25.2512-6(a), Example (3) .


35

   Tuttle, 436 F.2d 69 , 27 AFTR2d 71-354 , 71-1 USTC ¶9140 , 27 AFTR 2d 71-354


36

   Section 72(e) ; Blum, 150 F.2d 471 , 34 AFTR 24 , 45-2 USTC ¶9343 ; Avery, 111 F.2d 19 , 24 AFTR 856 , 40- 1 USTC ¶9405 ; Bodine, 103 F.2d 982 , 22 AFTR 1156 , 39-1 USTC ¶9450 . But see Ltr. Rul. 8943014 (“There would appear to be no current authority that an insurance policy is not a capital asset within ... section 1221”).


37

   Reg. 1.170 A-4(a) Reg. 1.170 A-4(a) .


38

   Rev. Rul. 69-102, 1969-1 CB 32 ; Friedman, 41 TC 428 , 346 F.2d 506 , 15 AFTR2d 1174 , 65-2 USTC ¶9473 .


39

   Reg. 1.170A-13(c) .


40

   Section 170(f)(8) .


41

   Reg. 25.2511-1(h)(8) .


42

   Rev. Rul. 76-200, 1976-1 CB 308 .


43

   Estate of Headrick, 918 F.2d 1263 , 66 AFTR2d 90-6038 , 90-2 USTC ¶60,049 , 66 AFTR 2d 90-6038 .


44

   Reg. 53.4944-1(a)(2)(ii)(a) .


45

   Rev. Rul. 80-133, 1980-1 CB 258 .


46

   Rev. Rul. 80-132, 1980-1 CB 255 .


47

   Section 514(a)(1) .


48

   Mose & Garrison Siskin Memorial Foundation, 790 F.2d 480 , 57 AFTR2d 86-1409 , 86- 1 USTC ¶9399 , 57 AFTR 2d 86-1409


49

   Sections 163(a) and 264 .


50

   Ltr. Rul. 7928014 .


51

   Regs. 1.664-3(b) and 1.664-2(b) .


52

  1980-1 CB 258.


53

   Section 664(c) ; Reg. 1.664-1(c) .


54

   Reg. 1.664-1(a)(4) .


55

  See Section 664(d)(3) .


56

   Section 677(a)(3) .


57

   Section 72(u) .


58

   Reg. 1.664-3(b)(1) ; Section 643(b) .


59

   Reg. 1.643(b)-1 .


60

   Ltr. Rul. 9009047 . See also Ltr. Rul. 9018015 (CRUT funded with a zero coupon bond); Teitell, “Some Good Ways for Generous Individuals to Keep Those “1000 Points of Light” Shining—Aided by 28 (or 33) Points of Tax Savings,” 129 Trusts & Estates 51 (Jul 1990).

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