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 30




                                       - 30 -                                         
          Dr. Durante         931250795PR     50,000     50,000                       
          Ms. Quinn           931250796PR     12,000     12,000                       
           Total1                            587,750    585,000                       
                    1 We recognize that VRD/RTD deducted for 1993                     
          contributions totaling $585,000.  In that the premiums paid                 
          in 1993 totaled $587,750, we are unable to find in the record               
          an explanation as to who paid the extra $2,750.                             
          The funds used to pay the premiums attributable to the two                  
          policies written on the lives of one or both of the DeAngelises             
          came from Dr. DeAngelis’s PC, the funds used to pay the premiums            
          attributable to the two policies written on the lives of one or             
          both of the Domingos came from Dr. Domingo’s PC, and the funds              
          used to pay the premiums for the policy written on the life of              
          Dr. Durante (Dr. Durante policy) came from his PC.  The funds               
          used to pay the premiums attributable to the policy written on              
          the life of Ms. Quinn (Ms. Quinn policy) were taken on some                 
          apportioned basis from all five PCs that were partners in                   
          VRD/RTD.13  In each of those cases, the funds used to pay the               
          premiums went from each PC to VRD/RTD, from VRD/RTD to the STEP             
          plan, and from the STEP plan to MetLife.                                    
               C.  Additional Correspondence                                          
              On September 19, 1995, Mr. Katz provided Mr. Freeman with              
          revised illustrations for the life insurance policies written               
          with respect to Drs. DeAngelis and Domingo.  Those illustrations            


               13 As discussed above, the record does not allow the Court             
          to find the specifics of that apportionment other than as to Dr.            
          Capizzi’s PC.                                                               





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