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schedules to limit the benefits payable to employees other than
the owners themselves;
5. Trust assets would be insulated from creditors;
6. Death benefits would not be subject to income tax or,
with minimal planning, estate tax.
As of December 31, 1994, approximately 800 employers had
participated in the Prime Plan. On that date, approximately
625 of these employers continued to participate in the Prime
Plan.
C. David Weiss
Mr. Weiss is an attorney who was employed during the
relevant years by the law firms of Streich Lang and Snell &
Wilmer. In early 1988, Prime contacted Mr. Weiss to help create
a welfare benefit plan subject to section 419A(f)(6) and to draft
a tax opinion that would be used to market the plan nationwide.
Mr. Weiss initially refused, believing there was insufficient
guidance on section 419A(f)(6) to allow him to create such a
plan. Mr. Weiss later agreed to do so. Mr. Weiss was a
principal architect of the Prime Plan and the Trust, and he wrote
a series of tax opinion letters related thereto. These letters
included opinions dated June 2, 1988, July 25, 1988, April 12,
1989, June 30, 1990, October 1, 1991, and April 1, 1993.
D. Dr. William L. Raby
Dr. Raby is an accountant with a national reputation in
areas related to the Prime Plan and the Trust. At the behest of
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