Winn-Dixie Stores, Inc. and Subsidiaries - Page 34




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                                                  COI Plus                            
                     Policy      Cash Paid By     Expense                             
                     Year        Petitioner      Charges                              
                     1993        $7,178,860     $6,767,008                            
                     1994        10,121,216     9,362,379                             
                     1995        14,578,925     13,407,466                            
                     1996        13,116,277     14,164,056                            
                     Total  44,995,278          43,700,909                            
          For the first 4 COLI policy years, beginning March 1, 1993, AIG             
          billed petitioner $431,049,000 in gross premiums and $69,774,925            
          in interest charges.  Gross premiums and interest charges totaled           
          $500,823,925.  Of this total amount, petitioner remitted the                
          above-calculated $44,995,27832 in cash.                                     
               Following the enactment of tax law changes in 1996,                    
          petitioner commenced discussions with AIG, Coventry, and WJ                 
          concerning the phaseout or discontinuance (unwind) of the COLI              
          policies.  These discussions concerned the approximately 36,000             
          policies purchased by petitioner in 1993 plus approximately                 
          11,000 and 9,000 COLI policies purchased in 1994 and 1995,                  
          respectively.  On October 22, 1996, Mr. McCook sent a letter to             
          Mr. Qureshi, vice president of AIG, which stated:                           
               Winn-Dixie has used AIG policies on three corporate                    
               owned life insurance (COLI) programs over the last                     
               several years.  Because of the recent tax law changes,                 
               we have been working with Alan Buerger of the Coventry                 
               Group and Bruce Hlavacek of Wiedemann and Johnson, to                  
               try to minimize the financial impact on Winn-Dixie for                 
               the phase out of COLI.                                                 
          Mr. Qureshi responded to Mr. McCook's October 22, 1996, letter              

               32See preceding table for cash total.                                  





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