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plan were used to pay the initial year’s cost of providing life
insurance for each participating doctor and to create an
investment fund for the insured within his whole life insurance
policy (or policies in the cases of Drs. DeAngelis and Domingo).
That fund, when enhanced with expected future dividends, was
calculated to be sufficient to pay for the future years’ costs of
life insurance protection and to provide for cash values
sufficient to allow for a distribution of cash to the insured
doctor whenever he opted to claim that he was involuntarily
terminated from his business. As to each investment fund (and as
to each insurance policy in general), the insured doctor regarded
that fund (and policy) as his own, as did the STEP plan trustee,
the STEP plan administrator, and MetLife. Very little (if any)
value in one participating doctor’s fund was available to pay to
another insured, and any distribution of cash from the STEP plan
to a participating doctor was directly related to the cash value
of his policy. In many instances, a participating doctor dealt
with his own insurance agent in selecting and purchasing the
policy on his life, received illustrations on an assortment of
life insurance investments that could be made through the STEP
plan, determined the amount of his investment in his life
insurance policy, selected the form of the insurance policy to be
issued for him (e.g., single whole life versus survivor whole
life), and selected his policy’s face amount. In the latter
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Last modified: March 27, 2008