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periodic policy value and other reports and journal entries
showing aggregate policy activity. The Coventry reports included
information about the CSR, experience rating, cash value
calculations, claims, refunds and recisions. The Coventry
reports also included information about the amount of tax savings
the COLI program was generating for petitioner.
From 1993 through 1996, petitioner kept the employee COLI
policies in force. AIG billed petitioner for premiums and
interest annually on a net basis, as set forth below:
June 1993, Policy year beginning March 1, 1993:
Premium $108,573,000
Loan (101,328,000)
Net premium 17,245,000
1A revised invoice was sent on Sept. 21, 1993, which reflected a
reduction in insureds from 36,191 to 35,983 due to a recision of 208
policies. Thus, the calculation was as follows:
Premium $107,949,000.00
Loan (100,770,140.06)
Net premium 7,178,859.94
Less amount paid (7,245,000.00)
Balance owed petitioner 66,140.06
Policy year beginning March 1, 1994:
Premium $107,862,000.00
Loan (108,877,159.95)
Interest 11,136,375.63
Balance due 10,121,215.68
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