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 24




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          benefits, that the usual form of payment would be in equal                  
          monthly installments over 24 months from the date of the                    
          employee’s termination, that the first installment would include            
          any payments delayed because of processing, and that severance              
          benefits could not exceed two times the employee’s last 12 months           
          of compensation before termination of employment.  The STEP plan            
          did not limit the amount of life insurance benefits that could be           
          received by a covered employee and stated that the optional life            
          insurance benefit (if elected) would be received in addition to             
          the severance benefit if the covered employee died while employed           
          by the participating employer.  The STEP plan stated that a                 
          participating employer could choose to withdraw from the plan,              
          that a participating employer could constructively withdraw from            
          the plan by failing to make an annual contribution or by                    
          violating a plan provision, and that upon withdrawal, any                   
          optional life insurance benefit could be discontinued or                    
          purchased from the plan by the employee or alternate insured at a           
          cost equal to the policy’s value (defined as the amount that                
          would be paid upon surrender of the coverage determined before              
          the application of surrender charges).  The STEP plan stated that           
          the optional life insurance benefit also could be discontinued if           
          the covered employee terminated service with the employer, the              
          employer failed to make a contribution with respect to the                  
          coverage, or the covered employee ceased to be a covered                    







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