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Drs. Hirshkowitz and Desai. Of the $70,000 paid to Peoples
Security, $50,000 was attributable to the coverage of Dr.
Hirshkowitz, and $20,000 was attributable to the coverage of Dr.
Desai.
On its 1993 Federal corporate income tax return, Lakewood
claimed a $296,055.90 deduction for VEBA contributions made for
the following persons’ benefits:
Trustee’s fees........ $1,000.00
Dr. Hirshkowitz.......211,119.90
Dr. Desai............. 55,000.00
Dr. Sobo.............. 15,000.00
Dr. Sankhla........... 5,750.00
Dr. McManus........... 18,186.00
296,055.90
1The Lakewood Plan returned this $5,000 to Lakewood in
October 1993.
This deduction consists of contributions to the Lakewood Plan and
$82,926.23 that Lakewood paid directly to Peoples Security for C-
group term policies purchased outside of the Lakewood Plan for
Drs. Hirshkowitz, Sankhla, and Desai. Of the $82,926.23 paid to
Peoples Security, $57,168.80 was attributable to the coverage of
Dr. Hirshkowitz, $5,750 was attributable to the coverage of Dr.
Sankhla, and $20,007.43 was attributable to the coverage of Dr.
Desai.
During the relevant years, the Lakewood Plan purchased 12
insurance policies on the lives of Lakewood’s principals. The
attributes of these policies are as follows.
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