Michael J. Kulzer & Jan K. Bielman-Kulzer - Page 12




                                        -11-                                          
          18        180,699   25,000    155,699   13,456   169,155                    
          19        169,155   25,000    144,155   12,532   156,688                    
          20        156,688   25,000    131,688   11,535   143,223                    
          21        143,223   25,000    118,223   10,458   128,680                    
          22        128,680   25,000    103,680    9,294   112,975                    
          23        112,975   25,000    87,975    8,038    96,013                     
          24        96,013    25,000    71,013    6,681    77,694                     
          25        77,694    25,000    52,694    5,216    57,909                     
          26        57,909    25,000    32,909    3,633    36,542                     
          27        36,542    25,000    11,542    1,923    13,466                     
               We note four preliminary points about petitioner's                     
          calculation.  First, the annual account balance is reduced by               
          $25,000 (see col. 4, above) before the stated interest rate, 8              
          percent, is applied to the balance (see col. 5, above).  The                
          amount of interest, thus computed, is then increased by $1,000.             
          Presumably, this $1,000 increase is intended to be the interest             
          on the $25,000 payment.  In making the calculation in this way,             
          we believe that the real rate of interest used in petitioner's              
          calculation is 7.5013149 percent, not 8 percent.                            
               Second, according to petitioner's calculation the account              
          balance is not fully amortized by the end of the 27th year.  As             
          shown in petitioner's schedule, reproduced above, there remains a           
          balance of $13,466 at the end of the 27th year.  Therefore,                 
          petitioner's calculation uses slightly more than 27 years to                
          amortize the account balance.                                               
               Third, petitioner states that the life expectancy of 27                
          years is based upon "an insurance mortality table" that he                  
          "found".  Significantly, this life expectancy is substantially              
          less than the life expectancy that would be determined in                   






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