Julie J. Revolinski and Kenneth T. White - Page 5

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          Pacific Life classified these distributions as policy loans.  For           
          each distribution, Pacific Life issued to petitioner a policy               
          loan statement indicating the amount of the loan, the interest              
          charged, and the outstanding loan balance.  Petitioner was not              
          required to sign any formal loan agreements with respect to these           
          distributions.  Petitioner never contacted Pacific Life regarding           
          the classification of these distributions as policy loans.                  
               Throughout the life of the policy, Pacific Life sent                   
          petitioner an account statement at the end of each policy year              
          reporting the following: Beginning accumulated value for the                
          year, premiums paid, premium load charge, cost of insurance                 
          charges (mortality charges, administrative charges, insurance               
          loads, and rider charges), interest earned, withdrawal amount,              
          dividends earned, the accumulated value at the end of the year,             
          current surrender charge, current loan debt (including unpaid               
          loan interest), and current cash surrender value.  According to             
          the account statements, the accumulated value of the policy on              
          July 16, 1988, increased from $5,729 to $23,467 as of July 16,              
          2001.                                                                       
               On August 7, 2001, petitioner surrendered the policy.  As of           
          that date, petitioner’s investment in the policy was $14,565, the           
          accumulated value was $23,509, the outstanding loans plus accrued           
          interest payable was $23,125, and the cash surrender value                  








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