Winn-Dixie Stores, Inc. and Subsidiaries - Page 20




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               The June 4 projections indicate that without tax savings               
          from policy loan interest and administration fee deductions, the            
          earnings effect over 60 years would have been a negative                    
          $681,922,000.  The tax savings over 60 years for interest and fee           
          deductions were projected to be $2,696,038,000.  After these tax            
          benefits are taken into consideration, the projection indicated             
          that petitioner would realize an after-tax profit of                        
          $2,014,115,000.  These after-tax financial benefits were                    
          dependent on the tax savings flowing from the interest and fee              
          deductions being generated by the broad-based COLI plan.                    
               Petitioner prepared a list of "Company Expense Reduction               
          Opportunities" for fiscal year 1993 that listed 23 items of                 
          savings that totaled $329,093,000.  The largest item of expense             
          reduction on the list is "Proposed Corporate Life Insurance                 
          (COLI)".  The list shows that this item (COLI) was estimated to             
          be implemented on June 30, 1993, and that petitioner's estimated            
          savings from COLI was $300 million.  Mr. McCook testified that he           
          thought this figure was derived from the "After-Tax Earnings                
          Effect" shown in column J of appendix A.21                                  
               AIG is a major underwriter of COLI policies.  AIG had been             
          working with WJ/Coventry in preparing the COLI plan.  Mr. Qureshi           


               21Three hundred million dollars is the approximate total of            
          the annual "After-Tax Earnings" projected for the policy years              
          1993 through 2007.  The total projected After-Tax Earnings for              
          the years 1993 through 2052 is $2,246,431,000.  See appendix A.             




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