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 46




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          surrenders and withdrawals on an employee-by-employee basis                 
          within each employer group, further segregated by each of the               
          eight insurance companies participating in the STEP plan.  STEP             
          maintained its books and records first by insurance company,                
          second by employer group, and finally by each individual                    
          employee.  Forms 5500-C/R, Return/Report of Employee Benefit                
          Plan, filed by the STEP plan were generally broken down by                  
          insurance company, employer group, and employee.  Forms W-2, Wage           
          and Tax Statement, were issued to participants with separate                
          employer identification numbers for each life insurance company.            
               Each insurance policy was essentially a separate account for           
          the covered employee on whose life the policy was written.  The             
          account included all of the employer’s contributions for that               
          employee, was increased by all of the income earned as a result             
          of those contributions, was reduced by all insurance company                
          charges to provide the life insurance benefits for only that                
          employee, and was used as the base from which to calculate the              
          purported severance benefits of that employee.  A severance                 
          benefit that was paid out to an employee was typically not equal            
          to what had been paid in by way of employer contributions.  The             
          employer contribution was invested by STEP, and the assets grew.            
               VRD/RTD’s contributions were invested in the individual                
          insurance policies of the participating doctors and Ms. Quinn.              
          The contributions for each policy were accounted for separately.            







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