- 12 -
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
Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: March 27, 2008