Winn-Dixie Stores, Inc. and Subsidiaries - Page 35




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          and acknowledged the recent change in the law with respect to the           
          COLI policies.  Mr. Qureshi also indicated that AIG would be                
          pleased to discuss various options available to petitioner.                 
               Coventry prepared a draft booklet dated October 30, 1996,              
          which contained, among other things, an overview of the current             
          status of petitioner's COLI pool, an opinion of the financial               
          effect of the 1996 tax law change, and explanations of several              
          exit and unwind strategies.  The draft booklet indicated that               
          petitioner had three separate enrollments covering approximately            
          55,740 lives.  The first enrollment "WD1" was in relation to the            
          policies written in 1993 covering 35,810 employees.  The second             
          enrollment "WD2" was in relation to the policies written on                 
          November 30, 1994, covering 10,704 employees.  The third                    
          enrollment "WD3" was written on June 30, 1995, and covered 9,226            
          employees.  With respect to the effect of the 1996 tax law                  
          changes on petitioner's COLI policies, the booklet stated in                
          pertinent part:                                                             
               In August of 1996, Congress amended the Internal                       
               Revenue Code was [sic] to deny deductions for any                      
               interest on policy loans on the lives of employees,                    
               officers, and persons financially interested in a trade                
               or business maintained by the taxpayer.  The                           
               disallowance was retroactive to January 1, 1996, except                
               that deductions may be continued through 1998 on up to                 
               20,000 policies.  The deduction on those policies,                     
               however, must be based on an interest rate no higher                   
               than Moody's average corporate bond rate, and only 90%                 








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