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 29




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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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