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commissions on the sales of the life insurance policies; e.g.,
$605,053 in 1994.
Drs. DeAngelis, Domingo, and Durante (collectively,
participating doctors) participated in the STEP plan through
their PCs and VRD/RTD. Alvin Rapp (Mr. Rapp) was an authorized
insurance agent of MetLife, and he recommended that all
contributions to the STEP plan made on behalf of the
participating doctors be invested in whole life insurance
policies issued by MetLife. That recommendation was followed.
Each whole life insurance policy related to a participating
doctor required that a payment be made annually on December 28
for the policy year beginning on that date.
B. Formation of the STEP Plan
The originator of the STEP concept was Kenneth L. Katz (Mr.
Katz), an insurance agent credentialed as a chartered life
underwriter and a chartered financial consultant. In 1988, Mr.
Katz asked his friend, Jeffrey Mamorsky (Mr. Mamorsky), to draft
a plan that could be marketed as a tax-beneficial welfare
benefits fund that complied with section 419A(f)(6). Mr.
Mamorsky was an attorney practicing primarily in the area of
employee benefits and compensation. Mr. Mamorsky later also
served as counsel to the STEP plan; in that capacity, Mr.
Mamorsky was available and willing to discuss with covered
employees (at the expense of the STEP plan) the manner in which
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Last modified: March 27, 2008