Internal Revenue Service v. CM Holdings, Inc. (In Re CM Holdings, Inc.)

OPINION

SCHWARTZ, Senior District Judge.

TABLE OF CONTENTS

I. INTRODUCTION.581

II. BACKGROUND.

A. General Background of Life Insurance .

1. Whole Life Insurance.

2. Universal Life Policy.

B. Development of the MBL COLI VIII Policy and Plan.

C. Camelot’s Decision to Purchase the MBL COLI VII Plan_

D. Features of Camelot’s COLI VIII Policies and Plan.

1. Amounts Due Each Policy Year (Columns (2), (3), and (4))

2. Sources of Funds to Pay Amounts Due (Columns (5), (6), (7), and (8))

a. Policy Years One through Three.

b. Policy Years Four through Seven.

3. Loan Interest Rate and Differential Crediting Rates.

4.…