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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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