Winn-Dixie Stores, Inc. and Subsidiaries - Page 18




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          1993, and the second was sent on June 4, 1993.  Both projections            
          were based on issuance of the proposed policies effective as of             
          March 1993.  The first set of revised projections assumed that              
          petitioner's taxes were paid at a rate of 40 percent19 for                  
          purposes of predicting the tax effect of the COLI purchase on               
          petitioner's financial ratios.  The second set of revised                   
          projections used a tax rate of 39 percent20  and assumed just               
          over 36,000 of petitioner's employees would be insured.  This               
          projection also assumed that maximum loans would be made in most            
          years but that cash withdrawals would be made in policy years 4             
          through 7 and policy years 16 through 21.  The June 4, 1993,                
          projections are attached as appendix B.                                     
               Using the same basic analysis that had been used in the                
          January projections, the June 4, 1993, projections again                    
          indicated that petitioner would sustain a pretax loss and a                 
          posttax profit on the COLI policies for every year the plan                 
          remained in effect.  See appendix B.  Thus, for the years 1993              
          through 2052, the June 4, 1993, projections indicated the broad-            
          based COLI plan would affect petitioner's profit and loss as                
          follows:                                                                    





               19See supra note 11.                                                   
               20See supra note 11.                                                   




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