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“The point of LTR 9810005 was for the doctors to have the promises funded, have the funds beyond the reach of creditors, have the setting aside of the funds to go untaxed, and have the investment go untaxed. In short, the doctors sought to obtain the benefits of a qualified retirement plan without the accompanying restrictions.” (Page 1462 of Tax Notes March 23, 1998 by tax expert and author – Lee A Sheppard.”
…The doctors get a printout of their stake in this fund at regular intervals. The IRS allowed the exception but only on the marginal theory that the public good might outweigh the private benefit.