CHAD A. READLER, Circuit Judge. A rambunctious groundhog’s turn-of-the-twentieth century antics led to the creation of a Northwest Ohio community treasure and, more recently, a federal tax dispute. To understand why, turn back the clock to the spring of 1900, when an overgrown groundhog ran loose in the furniture store of Toledo businessman Carl Hillebrand. A quandary arose. On one hand, the marmot posed a grave risk to Hillebrand’s inventory. True to their “woodchuck” alias, groundhogs are known to gnaw on wood, including furniture. And this one evidently had a penchant for chewing. Yet on the other hand, Hillebrand, to his credit, did not want to exterminate his furry visitor. But a solution would soon surface. As luck would have it, local park officials had a growing interest in opening a zoo. So Hillebrand offered his pesky patron to a park superintendent, who gladly accepted, and in turn put the animal on display for visitors. Perhaps like those sizing up tax law at first blush, observers faced some initial confusion. Onlookers thought they were witnessing a baby bear, not a groundhog, on account of the animal’s large size. Word of the enclosed supposed omnivore quickly spread, with crowds flocking to witness the seeming hog-in-bear’s clothing. The exhibition did gangbusters. And with that, the Toledo Zoo was launched. See Toledo Stories: The Toledo Zoo: A Living History, at 4:23 (PBS television broadcast, aired Oct. 24, 2002). By any metric, the Zoo has achieved much success over the ensuing century-and-a- quarter. It has grown to house over 16,000 animals. Visit Our Animals, Toledo Zoo & Aquarium, https://perma.cc/K6DY-5Z7G (last visited July 9, 2025). It welcomes over one million visitors each year. See Toledo Zoo & Aquarium, 2023 Annual Report 6 (Aug. 14, 2024), https://perma.cc/96F4-82XB. And it has garnered accolades. See, e.g., Press Release, Jen Brassil, Dir. of Pub. Rels. & Commc’ns Events, Toledo Zoo & Aquarium, The Toledo Zoo Honored with the 2023-2024 CILC Pinnacle Award (Aug. 26, 2024, at 4:00 ET), https://perma.cc/HH3P-H3HU (announcing that the Toledo Zoo received the Center for Interactive Learning and Collaboration’s Pinnacle Award in recognition of its educational programming efforts). The Zoo’s success has no doubt been fueled by generations of generous donors, all dating back to Hillebrand. Count Peter McGowan, a Toledo-area dentist, among those altruistic ranks. For several years, McGown regularly donated to the Toledo Zoo. Although his contributions waned as his children aged, McGowan purportedly envisioned making another substantial gift later in life: No. 24-3228 McGowan v. United States Page 3 the cash value of his life insurance policy. The tax ramifications of McGowan’s complicated plan to potentially bestow that gift eventually resulted in federal court litigation, and now this appeal. McGowan’s case centers on the following arrangement: Over five years, McGowan’s solely owned dental practice, Peter E. McGowan DDS, Inc. (the Company), contributed $50,000 annually to two “subtrusts,” one of which owned a life insurance policy covering McGowan. If the policy paid out upon McGowan’s death, it would benefit his wife. But if the policy-owning subtrust failed to pay a premium during the policy’s life, the subtrust would surrender the policy and transfer all cash value proceeds to the other subtrust. The latter subtrust, in turn, would contribute the money to a charity of McGowan’s choice. Like Hillebrand, McGowan chose the Toledo Zoo. This collection of subtrusts and potential philanthropy was thought to deliver a series of financial benefits to the proclaimed donors. In tax returns McGowan and the Company (collectively, the taxpayers) filed, the Company deducted the policy premiums it paid, with McGowan reporting just a quarter of them as taxable income. But the IRS demurred, asserting that the agency’s “split-dollar” regulation required McGowan to include the full value of the policy’s economic benefits in his gross income and, separately, foreclosed the Company’s attempted deductions. See Treas. Reg. § 1.61-22. It accordingly assessed over $100,000 in unpaid taxes, penalties, and interest between the two parties for tax years 2014 and 2015. Litigation ensued, culminating in the district court’s award of summary judgment to the government. Because the taxpayers land firmly within the split-dollar regulation, McGowan must include the value of the policy’s economic benefits in his gross income each year, and the Company cannot deduct its annual premium payments. And because that regulation comports with our independent reading of the Internal Revenue Code, see I.R.C. §§ 61, 162(a), 419(a), we affirm.