Winn-Dixie Stores, Inc. and Subsidiaries - Page 10




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          cash strategy.2  The two scenarios for the zero-cash strategy               
          were outlined as follows:                                                   
               Scenario 1 - Constant Loan Interest Scenario.  In this                 
               scenario, it is assumed that Winn-Dixie's appetite for                 
               interest deductions remains large, and policy interest                 
               is charged at 11.06% throughout the life of the COLI                   
               Pool.  This scenario results in the largest amount of                  
               earnings possible.                                                     
               Scenario 2 - Reducing Loan Interest Scenario.  In this                 
               scenario, Winn-Dixie's appetite for interest deductions                
               is assumed to reduce over time.  To adjust to the                      
               change in circumstances, the interest rate under the                   
               COLI Pool policies is reduced to 8% after the fifteenth                
               year.  This scenario generates a somewhat smaller tax                  
               arbitrage, but the resulting earnings are nevertheless                 
               significant.                                                           
          Included in the revised proposal memorandum dated January 27,               
          1993, were projections of petitioner's profit and loss, cash-               
          flow, and balance sheet balances under scenario 1, the constant             
          loan interest rate scenario, for the years 1993 through 2052.               
          The projections were based on the assumption that premiums paid             
          by petitioner would be financed by policy loans in all years                
          except years 4 through 7.  In the years 4 through 7, inclusive,             
          premiums were to be paid using funds from policy withdrawals.               
          The constant loan interest rate (scenario 1) projections included           
          in the January 27, 1993, memorandum are attached as appendix A.             


               2The Jan. 27, 1993, revised proposal assumed a pool covering           
          38,000 employees with an average premium of $3,000 per employee.            








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