- 22 -                                         
                         *    Front Fee           2.0                                 
                              Premium Tax         3.5%                                
                              Federal Excise Tax  1.0%                                
                                                  6.5%                                
          The $16,077,500 projected benefit to petitioner is the amount of            
          Federal income tax petitioner would have otherwise paid and is              
          based on the assumption that the underwriting profit, which was             
          referred to as the "UPS Insurance Subsidiary" in Bermuda, would             
          not be subject to Federal income tax.                                       
                              (2)  AIG/NUF                                            
               American International Group, Inc. (AIG), was a holding                
          company and the parent of over 500 subsidiary operating insurance           
          and subsidiary companies.  AIG Risk Management, Inc. (AIGRM), was           
          a subsidiary of AIG.  Mr. Joseph Smetana served as president and            
          CEO of AIGRM and senior vice president of NUF.  NUF was a wholly            
          owned subsidiary of AIG and operated as a domestic insurance                
          company.                                                                    
               On behalf of Hall, through a letter dated April 27, 1983,              
          Mr. Corde contacted Mr. Smetana.  In the letter, Mr. Corde                  
          apprised Mr. Smetana of petitioner's plan regarding the EVC's.              
          Mr. Corde indicated in the letter that petitioner's plan                    
          contemplated that the shippers' property handled by petitioner              
          would be insured under a master "Shippers Interest Policy".                 
          Further, the letter indicated that the contract of insurance                
          would be issued to petitioner and would cover the property of the           
          owners, shippers, consignees, or other interested parties.  With            
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