Paul Frehe Enterprises, Inc. - Page 5

          considered the lead actuarial cases.  The parties selected the              
          lead actuarial cases as a group in order to raise all or                    
          substantially all issues necessary to resolve the hundreds of               
          actuarial cases pending across the country.  The parties                    
          contemplated and understood that the lead actuarial cases were              
          considered a package.  The relevant dates for these cases are as            
          Tax Court       Tax Court                                                   
          Opinion        Decision      Appealed by      Disposition                   
            Filed         Entered       Commissioner      on Appeal                   
          Vinson & Elkins      7/14/92        9/14/92         12/10/92        11/29/93
          Wachtell, Lipton     7/14/92        2/16/93         05/12/93        06/06/94
          Citrus Valley        9/29/92        2/23/93         05/19/93        03/08/95
               The District Court for the Western District of Michigan                
          decided the issue of reasonableness of actuarial adjustments in             
          favor of the taxpayers.  Rhoades, McKee & Boer v. United States,            
          822 F. Supp. 445 (W.D. Mich. 1993), affd. in part and revd. in              
          part and remanded 43 F.3d 1071 (6th Cir. 1995).  On remand,                 
          however, the District Court found that the actuarial assumptions            
          used were not reasonable in the aggregate.  Rhoades, McKee & Boer           
          v. United States, 76 AFTR 2d 95-6394, 95-2 USTC par. 50,486 (W.D.           
          Mich. 1995).  We also note that in 1989 the Court of Appeals for            
          the Seventh Circuit found in favor of the Commissioner on similar           
          issues.  Jerome Mirza & Associates, Ltd. v. United States, 882              
          F.2d 229 (7th Cir. 1989).                                                   
               Neither the Court of Appeals for the Fifth Circuit's opinion           
          in Vinson & Elkins, nor the Court of Appeals for the Second                 

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