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minimize the Federal estate tax consequences to the family of the
insured, and Drs. DeAngelis and Domingo followed that
recommendation. STEP wanted any life insurance benefit to be
paid directly to the personal beneficiary of the insured, rather
than to or through the STEP plan, because STEP did not want the
STEP plan to be overfunded if and when it were to receive that
benefit.
Two annual premiums were paid on each of the six policies,
one for the policy year beginning December 28, 1993, and the
other for the policy year beginning December 28, 1994. As to
each policy, those premiums included the base premiums necessary
to fund the whole life insurance component of the policy and
premiums for PUAR. These payments were consistent with
illustrated payments contained in correspondence from Mr. Rapp.
The base premiums and PUAR premiums on the policies were as
follows:
Insured Policy # Base Premium PUAR Total
Dr. DeAngelis 931250799PR $81,596.64 $98,403.36 $180,000
Both DeAngelises 931250800A 103,762.66 16,237.34 120,000
Dr. Domingo 931250797PR 53,093.13 52,656.87 105,750
Both Domingos 931250798A 77,845.00 42,155.00 120,000
Dr. Durante 931250795PR 21,996.32 28,003.68 50,000
Ms. Quinn 931250796PR 6,173.67 5,826.33 12,000
Total 587,750
Premiums were paid in the 2 years as follows:
Insured Policy # 1993 1994
Dr. DeAngelis 931250799PR $180,000 $178,625
Both DeAngelises 931250800A 120,000 120,000
Dr. Domingo 931250797PR 105,750 104,375
Both Domingos 931250798A 120,000 120,000
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Last modified: March 27, 2008