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 36




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          withdrawal of $21,407 from the PUAR, and a policy loan of                   
          $46,820.  The premium due on December 28, 1997, was not paid                
          timely, and the policy lapsed for nonpayment of the premium.                
          MetLife converted the policy to reduced paid-up insurance with a            
          face value of $511,542.                                                     
               On or about October 19, 1999, upon the request of Dr.                  
          Domingo (and in connection with the above-referenced similar                
          request of Dr. DeAngelis), the Domingos survivor whole life                 
          policy was reinstated by MetLife to the full face value and                 
          converted retroactively to a policy with an APL provision.  That            
          feature was then applied to pay the premiums of $77,845 due on              
          December 28, 1997 and 1998, through an APL of $155,690.                     
          MetLife’s stated reason for reinstating the Domingos survivor               
          whole life policy in 1999 was that the policy had lapsed because            
          of “company error”; specifically, MetLife stated, Dr. Domingo               
          wanted loans to be made automatically from the policy to pay                
          premiums and was not advised by the broker that the policy was              
          set up with a nonforfeiture option of reduced paid-up insurance.            
          The Domingos survivor whole life policy lapsed again after the              
          nonpayment of the premium due on December 28, 1999 (the cash                
          value in the policy was insufficient to support an APL), and in             
          2000 was converted to participating reduced paid-up insurance               
          with a face value of $579,263.                                              








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