- 4 - petitioner was drawn on an account in the name of "Stable Reserve, Inc." Petitioner instructed Schwab to delay the deposit of petitioner's $40,653 premium check to Royal for a few days in order to permit petitioner's deposit of the $40,653 Stable Reserve check from Schwab to fund petitioner's check. In addition to remitting the two checks, petitioner signed a document that contained the recitation that the $40,653 check payment to him from Stable Reserve (Schwab) was a nonrecourse loan. Petitioner and Schwab understood that the signed document reciting the existence of a nonrecourse loan was prepared and executed in the event that the Internal Revenue Service looked into their insurance transaction and that the document had no substance or effect. Beginning in 1991, petitioner and his beneficiary(ies) had the benefit of $1,250,000 in life insurance coverage from Royal. The coverage was under a universal life policy, which differs from a whole life policy in that a universal life policy more closely reflects current interest rates thereby improving the accumulation of cash value. The $40,653 premium paid by petitioner was competitive with the premium charged by insurance companies other than Royal. Schwab, in turn, was entitled to a commission approximating 118 percent of the $40,653 1-year's premium on petitioner's Royal life insurance policy.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011