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 59




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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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