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 13

                                       - 13 -                                         
          The four versions executed in or after 1993 were stated as                  
          effective as of January 1, 1993.6                                           
               C.  Trustees, Administrators, and Sponsors                             
               Connecticut National Bank was the STEP plan trustee from the           
          plan’s inception through April 1, 1992.  The successor trustees             
          were United States Trust Co. of New York (U.S. Trust), Mellon               
          Trust of New York (Mellon Trust), and STEP Plan Services, Inc.              
          (SPSI).  U.S. Trust served as trustee from April 1, 1992, through           
          February 14, 1997; Mellon Trust served as trustee from                      
          February 14, 1997, through February 2002; and SPSI served as                
          trustee from February 2002 to date.                                         
               STEP, Inc., served as the STEP plan administrator from the             
          plan’s inception through July 26, 1990.  Teplitzky & Co., L.L.C.            
          (Teplitzky & Co.), acting primarily through its principal Jeffrey           
          Teplitzky (Mr. Teplitzky), was the successor plan administrator             
          from July 26, 1990, through February 7, 2002.  The current plan             
          administrator is SPSI.  During the relevant time, Daniel E.                 
          Carpenter (Mr. Carpenter) had sole signatory authority on behalf            
          of SPSI and served as its chairman.                                         

               6 There is also a 1992 version of the STEP plan for MetLife            
          and, beginning in February 1997, separate plans and trusts for              
          the eight insurance companies whose policies were sold through              
          STEP.  According to petitioners, the participating doctors were             
          covered by version 3 when VRD/RTD adopted the STEP plan on or               
          about Dec. 20, 1993, and were covered by version 4 as of Dec. 29,           

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