Metrocorp, Inc. - Page 74




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          with significant future benefits.  See U.S. Bancorp & Consol.               
          Subs. v. Commissioner, 111 T.C. 231 (1998).  Even if one were to            
          agree with the majority that the entrance and exit fees were paid           
          in order to terminate burdensome insurance premium obligations,             
          the entrance and exit fees would still fall within the rubric of            
          long-term benefits.                                                         
               For all the foregoing reasons, I respectfully dissent.                 
               RUWE, WHALEN, and GALE, JJ., agree with this dissenting                
          opinion.                                                                    

































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