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 40




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          Ms. McDermott had agreed to reinstate the policy as a reduced               
          paid-up policy retroactive to December 28, 1997.  Subsequently,             
          pursuant to the request of Dr. Domingo, MetLife changed the Dr.             
          Domingo policy to reduced paid-up insurance retroactively                   
          effective to December 28, 1997, with a face value of $195,924.              
          MetLife stated in part that it was making this change because               
          neither Dr. Domingo nor the STEP plan trustee had received timely           
          notice of either the lapse of the policy or multidistrict                   
          litigation involving MetLife’s marketing practices; the trustee             
          had directed MetLife to send all mail to the trustee in care of             
          the STEP plan administrator.  Following this change, the Dr.                
          Domingo policy has continued as participating reduced paid-up               
          insurance.                                                                  
               From December 28, 1993, through the present, Dr. Domingo               
          received life insurance coverage of $195,924 to $1,377,206                  
          through the Dr. Domingo policy.  As of December 28, 2005, the               
          policy’s death benefit and net cash surrender value were                    
          $267,034.57 and $185,025.58, respectively.                                  
               C.  Dr. DeAngelis Policy                                               
               On or about January 24, 2002, the ownership of the Dr.                 
          DeAngelis policy was changed to his name.  Shortly thereafter,              
          the Dr. DeAngelis policy was changed from nonforfeiture extended            
          term insurance to participating reduced paid-up insurance                   
          retroactively effective to December 28, 1997, with a face value             







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