Rev. Rul. 69-79

The taxpayer made a contribution to a college by irrevocably assigning to it the cash surrender value of a paid up life insurance policy on his life. The college is an educational organization within the meaning of section 170(b)(1)(A)(ii) of the Internal Revenue Code of 1954. The college was given possession of the policy. However, the taxpayer retained the right to name or change the beneficiary and to assign the balance of the policy subject to the college's right to the cash surrender value of the policy. Upon the taxpayer's death, the college is entitled to the amount assigned to it, and the named beneficiary of the policy is entitled to receive the face amount of the policy less the amount assigned to the college. The college was also given the right to surrender the policy for its cash surrender value, or to borrow from the insurer a sum up to the amount of its interest, without the taxpayer's permission.

Held, the cash surrender value of the life insurance irrevocably assigned to the college is deductible as a charitable contribution by the taxpayer in the manner and to the extent provided by section 170 of the Code. Since the college is an educational organization, contributions to it qualify for the additional ten percent limitation provided by section 170(b)(1)(A) of the Code.