Louis Fusaro - Page 6

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          pension plan provided by the Director’s Guild of America -                  
          Producer Pension Plan (pension plan).  The basic plan was a                 
          defined benefit plan, and the supplemental plan was a defined               
          contribution plan.                                                          
               On July 19, 2000, petitioner was fully vested in both the              
          supplemental plan and the basic plan.  On June 30, 2000, his                
          account balance in the supplemental plan was $249,053.10.  As of            
          July 19, 2000, under the basic plan, petitioner’s payment that he           
          would receive at age 65 was $3,811.29 per month, payable as a               
          single-life annuity.  As of July 19, 2000, petitioner’s early               
          retirement benefit under the basic plan includes the payment that           
          he would receive at age 55.  Petitioner’s payment would be                  
          $2,667.90 per month, payable as a single-life annuity.                      
          Bankruptcy Proceeding                                                       
               On July 19, 2000, petitioner filed a voluntary petition                
          under chapter 7 of the U.S. Bankruptcy Code with the U.S.                   
          Bankruptcy Court for the Central District of California in                  
          Los Angeles, California.  Petitioner’s address on the bankruptcy            
          petition was in Hollywood, California.  At the time he filed the            
          bankruptcy petition, petitioner represented that the market value           
          of the pension plan was $241,928.69, of which $64,068.58 was                
          claimed by his former spouse.  Petitioner claimed his pension               
          plan as exempt property in the bankruptcy proceedings.  No                  
          objection was made to petitioner’s claim that the pension plan              






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