V.R. DeAngelis M.D.P.C. & R.T. Domingo M.D.P.C., V. R. DeAngelis M.D.P.C., Tax Matters Partner, et al. - Page 12

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          they should prepare their applications for benefits from the                
          plan.  The intent of the STEP plan was to create an incentive to            
          buy, and thus to generate the sale of, whole life insurance                 
          policies through a claim of permissible tax avoidance and the               
          ability to pay and deduct premiums on the purchased policies                
          which would eventually be transferred to and owned by the                   
          insureds.  Many participants in the STEP plan believed that the             
          plan was one of deferred compensation.                                      
               Mr. Mamorsky prepared an initial version of the STEP plan on           
          or about December 15, 1989, and Mr. Katz began operating the STEP           
          plan at that time.  Mr. Mamorsky prepared a second version of the           
          STEP plan in 1990.  Mr. Mamorsky wrote other and all versions of            
          the STEP plan through June 2001, with an understanding that the             
          deductibility of contributions was critical both to the                     
          marketability of the STEP plan and to the operation and existence           
          of STEP.  The various versions of the STEP plan through June 2001           
          included the following:                                                     
          Version 1:  Executed on December 15, 1989                                   
          Version 2:  Version 1 Amended and Restated on July 26, 1990                 
          Version 3:  Executed on January 30, 1992                                    
          Version 4:  Executed on December 29, 1993                                   
          Version 5:  Executed as of November 1, 1994                                 
          Version 6:  Executed as of February 14, 1997                                
          Version 7:  Executed as of June 11, 2001                                    

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