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 42




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          form, backdated to January 3, 2003, the day of VRD/RTD’s formal             
          termination of its participation in the STEP plan.                          
               On August 7, 2003, STEP informed Ms. Quinn that it had asked           
          MetLife to change the ownership of the Ms. Quinn policy from the            
          STEP trustee to Ms. Quinn and that any action to reinstate the              
          policy had to be made by Ms. Quinn.  One day later, MetLife                 
          informed SPSI that it had received STEP’s request to change the             
          ownership of the Ms. Quinn policy but MetLife’s records indicated           
          that the policy had expired and was no longer in force.  At the             
          request of Dr. DeAngelis, the Ms. Quinn policy was changed by               
          MetLife later in 2003 to reduced paid-up insurance retroactively            
          effective to December 28, 1997, with a face value of $34,135.  On           
          September 30, 2003, MetLife confirmed to Ms. Quinn that she was             
          the owner of the Ms. Quinn policy and that the policy was being             
          continued as reduced paid-up insurance in the amount of $34,135,            
          which would increase as dividends were credited to the policy.              
               On or after January 16, 2004, Ms. Quinn surrendered the Ms.            
          Quinn policy to MetLife and received a check from MetLife in the            
          amount of $15,573.69.  MetLife processed the check on January 27,           
          2004.  From December 28, 1993, through January 16, 2005, Ms.                
          Quinn received life insurance coverage of $34,135 to $410,881               
          through the Ms. Quinn policy.                                               










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