Robert D. Booth and Janice Booth, et al. - Page 7

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          this list of owners on December 31, 1989, as did William G.                 
          Stalnaker on December 31, 1990.  Mr. Tominac and the corporation            
          terminated their ownership interests in both entities during                
          1990, and Messrs. Franks and Stalnaker terminated their ownership           
          interests in the entities during 1991.  On December 31, 1991, the           
          outstanding stock of Financial and the limited partnership units            
          of Limited were held by Messrs. Cummings, Brody, Waldman, and               
          Boyarsky.                                                                   
               During the relevant years, Prime was an investment banking             
          and financial services firm that earned revenues mostly by                  
          investing and placing money.  Prime also earned revenues from               
          commissions and administrative services generated by the Prime              
          Plan.  Prime researched, developed, and began marketing the Prime           
          Plan in 1988.  The Prime Plan provided death benefits and                   
          dismissal wage benefits (DWB's) to qualifying employees of                  
          participating employers.                                                    
               On November 29, 1991, Prime filed for protection under                 
          Chapter 11 of the U.S. Bankruptcy Code.                                     
               B.  Development of the Prime Plan                                      
               Mr. Brody developed the concept of the Prime Plan in 1988 in           
          response to 1984, 1986, and 1987 tax legislation that limited the           
          tax benefits a small business owner derived from a pension plan.            
          Mr. Brody expected that the Prime Plan would provide meaningful             
          tax deferral to small businesses with few employees.  The Prime             
          Plan purported to enable business owners to make tax deductible             




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