Fred P. and Patricia M. Brandkamp - Page 4




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               Petitioner Patricia M. Brandkamp (Mrs. Brandkamp) was                  
          employed throughout 1997 by MetLife Insurance Co. (MetLife). Mrs.           
          Brandkamp was hired by MetLife in December 1995 and remained in             
          its employ through November 1998.                                           
               At all relevant times, MetLife maintained a defined benefit            
          pension plan (the MetLife plan) that was qualified within the               
          meaning of section 401(a).  An individual is eligible to                    
          participate in the MetLife plan if the individual: (1) Is at                
          least 21 years old, (2) is an active U.S. salaried or                       
          commissioned employee, and (3) has completed 1 year of continuous           
          or credited service.                                                        
               Once an employee is eligible to participate in the MetLife             
          plan, the employee is automatically enrolled in the plan at no              
          cost to the employee.  However, the employee does not have any              
          vested right to a pension benefit until the employee has                    
          completed 5 years of continuous or credited service.                        
               Mrs. Brandkamp became enrolled in the MetLife plan upon                
          completion of 1 year of service with MetLife in December 1996.              
          However, because Mrs. Brandkamp left the employ of MetLife before           
          completing 5 years of continuous or credited service with                   
          MetLife, her right to a pension benefit never vested.                       
               On April 13, 1998, Mr. Brandkamp contributed $2,000 to an              
          IRA that he maintained in his name with SouthTrust Bank in                  







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