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 27




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          accumulates any extra proceeds in the policy until needed to pay            
          premiums in a later year.                                                   
               As of December 28, 1993, MetLife issued the following six              
          life insurance policies with respect to VRD/RTD’s initial                   
          contribution to the STEP plan:                                              
          Insured               Policy #        Type of Policy       Face Value       
          Dr. DeAngelis          931250799PR    Whole life              $2,156,442    
          Both DeAngelises       931250800A     Survivor whole life      4,818,200    
          Dr. Domingo            931250797PR    Whole life               1,327,656    
          Both Domingos          931250798A     Survivor whole life      3,500,000    
          Dr. Durante            931250795PR    Whole life               1,804,135    
          Ms. Quinn              931250796PR    Whole life                 409,184    
          Four of these policies were individual whole life insurance                 
          policies separately insuring the lives of Ms. Quinn and each of             
          the participating doctors.  The other two policies were joint and           
          survivor whole life insurance policies (survivor whole life                 
          policies) or, in other words, life insurance that was not payable           
          to the beneficiary until the deaths of both insureds.  One                  
          survivor whole life policy insured both DeAngelises (DeAngelises            
          survivor whole life policy), and the other survivor whole life              
          policy insured both Domingos (Domingos survivor whole life                  
          policy).  Neither Jeanette DeAngelis nor Bernadette Domingo was             
          an employee of VRD/RTD, and the survivor whole life insurance               
          policies were purchased by Drs. DeAngelis and Domingo as part of            
          their Federal estate tax plans.  On December 28, 1993, Dr.                  
          DeAngelis was 60 years old, Jeanette DeAngelis was 61 years old,            
          and each of the Domingos was 61 years old.  Also on that date,              
          Dr. Durante was 37 years old, and Ms. Quinn was 38 years old.               





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