- 26 - the policy insuring the life of Ms. Quinn. Of the $10,000, Dr. Capizzi’s PC paid $2,400 in 1993 and $2,000 in 1994. The record does not allow the Court to find the portion of the $10,000 in either year that was paid by any of the other PC partners. During each of 1993 and 1994, VRD/RTD contributed $585,000 to the STEP plan and recorded each of these contributions as a “Pension Contribution”. VRD/RTD’s partnership return reported the forwarding fees received from the PCs as income and claimed a corresponding deduction for “Retirement plans, etc.” VRD/RTD did not make any further contribution to STEP, and neither STEP nor any petitioner directly paid any further premium on the subject life insurance policies after the premiums were paid on December 28, 1994, for the policy year beginning on that date. B. Issuance of Policies When VRD/RTD adopted the STEP plan, all of VRD/RTD’s contribution to the plan was invested in whole life insurance policies issued by MetLife and sold by Mr. Rapp. The particular policies were selected by the participating doctors in consultation with Mr. Rapp. All of the policies were participating whole life insurance polices, with the additional feature that extra premiums could be paid to purchase paid-up additions rider insurance (PUAR). A PUAR feature, when elected, essentially prefunds the annual premiums for a policy andPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 NextLast modified: March 27, 2008