Barbara E. Seaman - Page 17




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          respective dividend accumulations under those policies in order             
          to have been able to make such withdrawals of such interest.  We            
          disagree.                                                                   
               The Prudential policy provides in pertinent part:                      
                    Annual Dividends.--While this policy is in force                  
               * * *, the portion, if any, of the divisible surplus of                
               the Company accruing upon the policy at each policy                    
               anniversary will be determined annually by the Board of                
               Directors, and will be credited to the policy as a                     
               dividend on such anniversary * * *.                                    
                     *      *      *      *      *      *      *                      
                    Upon proper written request to the Home Office,                   
               any such dividend may be (1) paid in cash, or * * *                    
               (4) left to accumulate with compound interest at the                   
               rate authorized from time to time by the Board of                      
               Directors, but not less than 2½% per annum. * * * Upon                 
               proper written request to the Home Office, * * * any                   
               dividend accumulations may be withdrawn * * *.                         
               The USAA policy provides in pertinent part:                            
               DIVIDENDS.  At the end of the second Policy year and                   
               annually thereafter, * * * this Policy shall be cred-                  
               ited with such share of the divisible surplus of the                   
               participating business of the Company as may be appor-                 
               tioned thereto by the Company.                                         
               Options.  At the option of the Owner each dividend may                 
               be                                                                     
                    (a) paid in cash, or                                              
                     *      *      *      *      *      *      *                      
                    (d) left to accumulate to the credit of this                      
               Policy with interest, as determined by the Company, at                 
               not less than 2½% per annum, compounded annually (here-                
               inafter called dividend accumulation), or                              
                     *      *      *      *      *      *      *                      
               At any time * * * dividend accumulations * * * may be                  
               withdrawn.  * * *                                                      






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