id	sid	tid	token	lemma	pos
cblr-2960	1	1	job	job	NOUN
cblr-2960	1	2	well	well	ADV
cblr-2960	1	3	done	do	VERB
cblr-2960	1	4	:	:	PUNCT
cblr-2960	1	5	preventing	prevent	VERB
cblr-2960	1	6	the	the	DET
cblr-2960	1	7	use	use	NOUN
cblr-2960	1	8	of	of	ADP
cblr-2960	1	9	private	private	ADJ
cblr-2960	1	10	placement	placement	NOUN
cblr-2960	1	11	life	life	NOUN
cblr-2960	1	12	insurance	insurance	NOUN
cblr-2960	1	13	to	to	PART
cblr-2960	1	14	wrap	wrap	VERB
cblr-2960	1	15	hedge	hedge	NOUN
cblr-2960	1	16	fund	fund	NOUN
cblr-2960	1	17	investments	investment	NOUN
cblr-2960	1	18	job	job	NOUN
cblr-2960	1	19	well	well	ADV
cblr-2960	1	20	done	do	VERB
cblr-2960	1	21	:	:	PUNCT
cblr-2960	1	22	preventing	prevent	VERB
cblr-2960	1	23	the	the	DET
cblr-2960	1	24	use	use	NOUN
cblr-2960	1	25	of	of	ADP
cblr-2960	1	26	private	private	ADJ
cblr-2960	1	27	placement	placement	NOUN
cblr-2960	1	28	life	life	NOUN
cblr-2960	1	29	insurance	insurance	NOUN
cblr-2960	1	30	to	to	PART
cblr-2960	1	31	wrap	wrap	VERB
cblr-2960	1	32	hedge	hedge	NOUN
cblr-2960	1	33	fund	fund	NOUN
cblr-2960	1	34	investments	investments	PROPN
cblr-2960	1	35	stephen	stephen	PROPN
cblr-2960	1	36	d.	d.	PROPN
cblr-2960	1	37	chu	chu	PROPN
cblr-2960	1	38	*	*	PROPN
cblr-2960	1	39	i.	i.	PROPN
cblr-2960	1	40	introduction	introduction	NOUN
cblr-2960	1	41	................................................................	................................................................	PUNCT
cblr-2960	1	42	694	694	NUM
cblr-2960	1	43	ii	ii	NOUN
cblr-2960	1	44	.	.	PUNCT
cblr-2960	2	1	private	private	ADJ
cblr-2960	2	2	placement	placement	NOUN
cblr-2960	2	3	life	life	NOUN
cblr-2960	2	4	insurance	insurance	NOUN
cblr-2960	2	5	contracts	contract	NOUN
cblr-2960	2	6	...........	...........	PUNCT
cblr-2960	2	7	697	697	NUM
cblr-2960	2	8	iii	iii	NOUN
cblr-2960	2	9	.	.	PUNCT
cblr-2960	2	10	current	current	ADJ
cblr-2960	2	11	law	law	NOUN
cblr-2960	2	12	...............................................................	...............................................................	PUNCT
cblr-2960	2	13	702	702	NUM
cblr-2960	2	14	a.	a.	NOUN
cblr-2960	2	15	diversification	diversification	NOUN
cblr-2960	2	16	requirement	requirement	NOUN
cblr-2960	2	17	...............................	...............................	PUNCT
cblr-2960	2	18	702	702	NUM
cblr-2960	2	19	b.	b.	PROPN
cblr-2960	2	20	investor	investor	NOUN
cblr-2960	2	21	control	control	PROPN
cblr-2960	2	22	doctrine	doctrine	NOUN
cblr-2960	2	23	...................................	...................................	PUNCT
cblr-2960	2	24	703	703	NUM
cblr-2960	2	25	1	1	NUM
cblr-2960	2	26	.	.	PUNCT
cblr-2960	3	1	the	the	DET
cblr-2960	3	2	first	first	ADJ
cblr-2960	3	3	prong	prong	NOUN
cblr-2960	3	4	-	-	PUNCT
cblr-2960	3	5	control	control	NOUN
cblr-2960	3	6	by	by	ADP
cblr-2960	3	7	the	the	DET
cblr-2960	3	8	investor	investor	NOUN
cblr-2960	3	9	....	....	PUNCT
cblr-2960	4	1	705	705	NUM
cblr-2960	4	2	2	2	NUM
cblr-2960	4	3	.	.	PUNCT
cblr-2960	5	1	the	the	DET
cblr-2960	5	2	second	second	ADJ
cblr-2960	5	3	prong	prong	NOUN
cblr-2960	5	4	-	-	PUNCT
cblr-2960	5	5	insurance	insurance	NOUN
cblr-2960	5	6	-	-	PUNCT
cblr-2960	5	7	dedicated	dedicate	VERB
cblr-2960	5	8	funds	fund	NOUN
cblr-2960	5	9	o	o	X
cblr-2960	5	10	nly	nly	ADV
cblr-2960	5	11	.....................................................	.....................................................	PUNCT
cblr-2960	6	1	706	706	NUM
cblr-2960	6	2	a.	a.	NOUN
cblr-2960	6	3	private	private	ADJ
cblr-2960	6	4	letter	letter	NOUN
cblr-2960	6	5	ruling	rule	VERB
cblr-2960	6	6	2002	2002	NUM
cblr-2960	6	7	-	-	SYM
cblr-2960	6	8	44	44	NUM
cblr-2960	6	9	-	-	PUNCT
cblr-2960	6	10	001	001	NUM
cblr-2960	6	11	..........	..........	PUNCT
cblr-2960	6	12	707	707	NUM
cblr-2960	6	13	b.	b.	NOUN
cblr-2960	6	14	removal	removal	NOUN
cblr-2960	6	15	of	of	ADP
cblr-2960	6	16	regulation	regulation	NOUN
cblr-2960	6	17	section	section	NOUN
cblr-2960	6	18	1.8175(f)(2)(ii	1.8175(f)(2)(ii	NUM
cblr-2960	6	19	)	)	PUNCT
cblr-2960	6	20	....................................................	....................................................	PUNCT
cblr-2960	7	1	709	709	NUM
cblr-2960	7	2	iv	iv	NUM
cblr-2960	7	3	.	.	PUNCT
cblr-2960	8	1	m	m	PROPN
cblr-2960	8	2	ethods	ethod	NOUN
cblr-2960	8	3	of	of	ADP
cblr-2960	8	4	analysis	analysis	NOUN
cblr-2960	8	5	...................................................	...................................................	PUNCT
cblr-2960	8	6	710	710	NUM
cblr-2960	8	7	a.	a.	NOUN
cblr-2960	8	8	elasticity	elasticity	NOUN
cblr-2960	8	9	of	of	ADP
cblr-2960	8	10	taxable	taxable	ADJ
cblr-2960	8	11	income	income	NOUN
cblr-2960	8	12	and	and	CCONJ
cblr-2960	8	13	the	the	DET
cblr-2960	8	14	distortionary	distortionary	ADJ
cblr-2960	8	15	effect	effect	NOUN
cblr-2960	8	16	.............................................	.............................................	PUNCT
cblr-2960	8	17	711	711	NUM
cblr-2960	8	18	b	b	NOUN
cblr-2960	8	19	.	.	PUNCT
cblr-2960	9	1	f	f	PROPN
cblr-2960	9	2	rictions	riction	NOUN
cblr-2960	9	3	...............................................................	...............................................................	PUNCT
cblr-2960	10	1	712	712	NUM
cblr-2960	10	2	v.	v.	CCONJ
cblr-2960	10	3	effi	effi	PROPN
cblr-2960	10	4	ciency	ciency	NOUN
cblr-2960	10	5	analysis	analysis	NOUN
cblr-2960	10	6	.....................................................	.....................................................	PUNCT
cblr-2960	11	1	713	713	NUM
cblr-2960	11	2	a.	a.	NOUN
cblr-2960	11	3	having	have	VERB
cblr-2960	11	4	to	to	PART
cblr-2960	11	5	follow	follow	VERB
cblr-2960	11	6	the	the	DET
cblr-2960	11	7	rules	rule	NOUN
cblr-2960	11	8	.................................	.................................	PUNCT
cblr-2960	12	1	715	715	NUM
cblr-2960	12	2	1	1	NUM
cblr-2960	12	3	.	.	PUNCT
cblr-2960	12	4	loss	loss	NOUN
cblr-2960	12	5	of	of	ADP
cblr-2960	12	6	control	control	NOUN
cblr-2960	12	7	................................................	................................................	PUNCT
cblr-2960	13	1	715	715	NUM
cblr-2960	13	2	2	2	NUM
cblr-2960	13	3	.	.	PUNCT
cblr-2960	13	4	r	r	NOUN
cblr-2960	13	5	eluctance	eluctance	NOUN
cblr-2960	13	6	.......................................................	.......................................................	PUNCT
cblr-2960	14	1	716	716	NUM
cblr-2960	14	2	3	3	NUM
cblr-2960	14	3	.	.	PUNCT
cblr-2960	15	1	costs	cost	NOUN
cblr-2960	15	2	of	of	ADP
cblr-2960	15	3	com	com	NOUN
cblr-2960	15	4	pliance	pliance	NOUN
cblr-2960	15	5	.......................................	.......................................	PUNCT
cblr-2960	16	1	718	718	NUM
cblr-2960	16	2	4	4	NUM
cblr-2960	16	3	.	.	PUNCT
cblr-2960	16	4	external	external	ADJ
cblr-2960	16	5	constraints	constraint	NOUN
cblr-2960	16	6	......................................	......................................	PUNCT
cblr-2960	16	7	720	720	NUM
cblr-2960	16	8	b.	b.	ADJ
cblr-2960	16	9	tiny	tiny	ADJ
cblr-2960	16	10	fraction	fraction	NOUN
cblr-2960	16	11	of	of	ADP
cblr-2960	16	12	the	the	DET
cblr-2960	16	13	market	market	NOUN
cblr-2960	16	14	................................	................................	PUNCT
cblr-2960	17	1	722	722	NUM
cblr-2960	17	2	v	v	NOUN
cblr-2960	17	3	i.	i.	NOUN
cblr-2960	17	4	c	c	PROPN
cblr-2960	17	5	onclusion	onclusion	NOUN
cblr-2960	17	6	..................................................................	..................................................................	PUNCT
cblr-2960	17	7	722	722	NUM
cblr-2960	17	8	i.	i.	NOUN
cblr-2960	17	9	introduction	introduction	NOUN
cblr-2960	17	10	as	as	SCONJ
cblr-2960	17	11	the	the	DET
cblr-2960	17	12	economy	economy	NOUN
cblr-2960	17	13	continues	continue	VERB
cblr-2960	17	14	to	to	PART
cblr-2960	17	15	see	see	VERB
cblr-2960	17	16	a	a	DET
cblr-2960	17	17	significant	significant	ADJ
cblr-2960	17	18	rise	rise	NOUN
cblr-2960	17	19	in	in	ADP
cblr-2960	17	20	hedge	hedge	NOUN
cblr-2960	17	21	fund	fund	NOUN
cblr-2960	17	22	activity	activity	NOUN
cblr-2960	17	23	,	,	PUNCT
cblr-2960	17	24	investors	investor	NOUN
cblr-2960	17	25	continue	continue	VERB
cblr-2960	17	26	to	to	PART
cblr-2960	17	27	look	look	VERB
cblr-2960	17	28	for	for	ADP
cblr-2960	17	29	mechanisms	mechanism	NOUN
cblr-2960	17	30	that	that	PRON
cblr-2960	17	31	will	will	AUX
cblr-2960	17	32	mitigate	mitigate	VERB
cblr-2960	17	33	the	the	DET
cblr-2960	17	34	tax	tax	NOUN
cblr-2960	17	35	burden	burden	NOUN
cblr-2960	17	36	on	on	ADP
cblr-2960	17	37	their	their	PRON
cblr-2960	17	38	hedge	hedge	NOUN
cblr-2960	17	39	fund	fund	NOUN
cblr-2960	17	40	investments	investment	NOUN
cblr-2960	17	41	.	.	PUNCT
cblr-2960	17	42	'	'	PUNCT
cblr-2960	18	1	hedge	hedge	NOUN
cblr-2960	18	2	funds	fund	NOUN
cblr-2960	18	3	are	be	AUX
cblr-2960	18	4	lightly	lightly	ADV
cblr-2960	18	5	regulated	regulate	VERB
cblr-2960	18	6	investment	investment	NOUN
cblr-2960	18	7	pools	pool	NOUN
cblr-2960	18	8	that	that	PRON
cblr-2960	18	9	actively	actively	ADV
cblr-2960	18	10	trade	trade	VERB
cblr-2960	18	11	shares	share	NOUN
cblr-2960	18	12	in	in	ADP
cblr-2960	18	13	short	short	ADJ
cblr-2960	18	14	periods	period	NOUN
cblr-2960	18	15	of	of	ADP
cblr-2960	18	16	time	time	NOUN
cblr-2960	18	17	,	,	PUNCT
cblr-2960	18	18	generating	generate	VERB
cblr-2960	18	19	substantial	substantial	ADJ
cblr-2960	18	20	short	short	ADJ
cblr-2960	18	21	term	term	NOUN
cblr-2960	18	22	gains	gain	NOUN
cblr-2960	18	23	that	that	PRON
cblr-2960	18	24	are	be	AUX
cblr-2960	18	25	taxed	tax	VERB
cblr-2960	18	26	at	at	ADP
cblr-2960	18	27	up	up	ADP
cblr-2960	18	28	to	to	ADP
cblr-2960	18	29	35%.2	35%.2	NUM
cblr-2960	18	30	in	in	ADP
cblr-2960	18	31	an	an	DET
cblr-2960	18	32	attempt	attempt	NOUN
cblr-2960	18	33	to	to	PART
cblr-2960	18	34	avoid	avoid	VERB
cblr-2960	18	35	the	the	DET
cblr-2960	18	36	harsh	harsh	ADJ
cblr-2960	18	37	ordinary	ordinary	ADJ
cblr-2960	18	38	income	income	NOUN
cblr-2960	18	39	tax	tax	NOUN
cblr-2960	18	40	,	,	PUNCT
cblr-2960	18	41	taxpayers	taxpayer	NOUN
cblr-2960	18	42	may	may	AUX
cblr-2960	18	43	wrap	wrap	VERB
cblr-2960	18	44	the	the	DET
cblr-2960	18	45	hedge	hedge	NOUN
cblr-2960	18	46	fund	fund	NOUN
cblr-2960	18	47	interest	interest	NOUN
cblr-2960	18	48	within	within	ADP
cblr-2960	18	49	a	a	DET
cblr-2960	18	50	private	private	ADJ
cblr-2960	18	51	placement	placement	NOUN
cblr-2960	18	52	life	life	NOUN
cblr-2960	18	53	insurance	insurance	NOUN
cblr-2960	18	54	contract	contract	NOUN
cblr-2960	18	55	.	.	PUNCT
cblr-2960	18	56	'	'	PUNCT
cblr-2960	19	1	an	an	DET
cblr-2960	19	2	insurance	insurance	NOUN
cblr-2960	19	3	wrapper	wrapper	NOUN
cblr-2960	19	4	is	be	AUX
cblr-2960	19	5	a	a	DET
cblr-2960	19	6	life	life	NOUN
cblr-2960	19	7	insurance	insurance	NOUN
cblr-2960	19	8	contract	contract	NOUN
cblr-2960	19	9	in	in	ADP
cblr-2960	19	10	which	which	PRON
cblr-2960	19	11	a	a	DET
cblr-2960	19	12	portion	portion	NOUN
cblr-2960	19	13	of	of	ADP
cblr-2960	19	14	the	the	DET
cblr-2960	19	15	policyholder	policyholder	NOUN
cblr-2960	19	16	's	's	PART
cblr-2960	19	17	premium	premium	NOUN
cblr-2960	19	18	payment	payment	NOUN
cblr-2960	19	19	is	be	AUX
cblr-2960	19	20	invested	invest	VERB
cblr-2960	19	21	in	in	ADP
cblr-2960	19	22	a	a	DET
cblr-2960	19	23	hedge	hedge	NOUN
cblr-2960	19	24	fund.4	fund.4	NOUN
cblr-2960	19	25	because	because	SCONJ
cblr-2960	19	26	the	the	DET
cblr-2960	19	27	hedge	hedge	NOUN
cblr-2960	19	28	fund	fund	NOUN
cblr-2960	19	29	interests	interest	NOUN
cblr-2960	19	30	are	be	AUX
cblr-2960	19	31	held	hold	VERB
cblr-2960	19	32	within	within	ADP
cblr-2960	19	33	an	an	DET
cblr-2960	19	34	insurance	insurance	NOUN
cblr-2960	19	35	policy,5	policy,5	NOUN
cblr-2960	19	36	gains	gain	NOUN
cblr-2960	19	37	on	on	ADP
cblr-2960	19	38	the	the	DET
cblr-2960	19	39	investments	investment	NOUN
cblr-2960	19	40	are	be	AUX
cblr-2960	19	41	shielded	shield	VERB
cblr-2960	19	42	from	from	ADP
cblr-2960	19	43	tax	tax	NOUN
cblr-2960	19	44	.	.	PUNCT
cblr-2960	19	45	'	'	PUNCT
cblr-2960	20	1	policyholders	policyholder	NOUN
cblr-2960	20	2	may	may	AUX
cblr-2960	20	3	also	also	ADV
cblr-2960	20	4	be	be	AUX
cblr-2960	20	5	able	able	ADJ
cblr-2960	20	6	to	to	PART
cblr-2960	20	7	access	access	VERB
cblr-2960	20	8	their	their	PRON
cblr-2960	20	9	money	money	NOUN
cblr-2960	20	10	during	during	ADP
cblr-2960	20	11	their	their	PRON
cblr-2960	20	12	lifetimes	lifetime	NOUN
cblr-2960	20	13	by	by	ADP
cblr-2960	20	14	withdrawing	withdraw	VERB
cblr-2960	20	15	or	or	CCONJ
cblr-2960	20	16	*	*	PUNCT
cblr-2960	20	17	j.d	j.d	PROPN
cblr-2960	20	18	.	.	PROPN
cblr-2960	20	19	candidate	candidate	NOUN
cblr-2960	20	20	2009	2009	NUM
cblr-2960	20	21	,	,	PUNCT
cblr-2960	20	22	columbia	columbia	PROPN
cblr-2960	20	23	university	university	PROPN
cblr-2960	20	24	school	school	NOUN
cblr-2960	20	25	of	of	ADP
cblr-2960	20	26	law	law	NOUN
cblr-2960	20	27	;	;	PUNCT
cblr-2960	20	28	b.a	b.a	PROPN
cblr-2960	20	29	.	.	PROPN
cblr-2960	20	30	history	history	PROPN
cblr-2960	20	31	2006	2006	NUM
cblr-2960	20	32	,	,	PUNCT
cblr-2960	20	33	columbia	columbia	PROPN
cblr-2960	20	34	university	university	PROPN
cblr-2960	20	35	.	.	PUNCT
cblr-2960	21	1	the	the	DET
cblr-2960	21	2	author	author	NOUN
cblr-2960	21	3	wishes	wish	VERB
cblr-2960	21	4	to	to	PART
cblr-2960	21	5	thank	thank	VERB
cblr-2960	21	6	his	his	PRON
cblr-2960	21	7	family	family	NOUN
cblr-2960	21	8	,	,	PUNCT
cblr-2960	21	9	professor	professor	PROPN
cblr-2960	21	10	alex	alex	PROPN
cblr-2960	21	11	raskolnikov	raskolnikov	PROPN
cblr-2960	21	12	for	for	ADP
cblr-2960	21	13	his	his	PRON
cblr-2960	21	14	guidance	guidance	NOUN
cblr-2960	21	15	,	,	PUNCT
cblr-2960	21	16	allison	allison	PROPN
cblr-2960	21	17	snyder	snyder	PROPN
cblr-2960	21	18	for	for	ADP
cblr-2960	21	19	her	her	PRON
cblr-2960	21	20	support	support	NOUN
cblr-2960	21	21	,	,	PUNCT
cblr-2960	21	22	and	and	CCONJ
cblr-2960	21	23	the	the	DET
cblr-2960	21	24	staff	staff	NOUN
cblr-2960	21	25	of	of	ADP
cblr-2960	21	26	the	the	DET
cblr-2960	21	27	columbia	columbia	PROPN
cblr-2960	21	28	business	business	PROPN
cblr-2960	21	29	law	law	PROPN
cblr-2960	21	30	review	review	NOUN
cblr-2960	21	31	for	for	ADP
cblr-2960	21	32	their	their	PRON
cblr-2960	21	33	editing	editing	NOUN
cblr-2960	21	34	assistance	assistance	NOUN
cblr-2960	21	35	.	.	PUNCT
cblr-2960	21	36	'	'	PUNCT
cblr-2960	22	1	"	"	PUNCT
cblr-2960	22	2	over	over	ADP
cblr-2960	22	3	the	the	DET
cblr-2960	22	4	last	last	ADJ
cblr-2960	22	5	decade	decade	NOUN
cblr-2960	22	6	,	,	PUNCT
cblr-2960	22	7	the	the	DET
cblr-2960	22	8	growth	growth	NOUN
cblr-2960	22	9	of	of	ADP
cblr-2960	22	10	hedge	hedge	NOUN
cblr-2960	22	11	funds	fund	NOUN
cblr-2960	22	12	has	have	AUX
cblr-2960	22	13	accelerated	accelerate	VERB
cblr-2960	22	14	dramatically	dramatically	ADV
cblr-2960	22	15	,	,	PUNCT
cblr-2960	22	16	in	in	ADP
cblr-2960	22	17	terms	term	NOUN
cblr-2960	22	18	of	of	ADP
cblr-2960	22	19	both	both	DET
cblr-2960	22	20	assets	asset	NOUN
cblr-2960	22	21	under	under	ADP
cblr-2960	22	22	management	management	NOUN
cblr-2960	22	23	and	and	CCONJ
cblr-2960	22	24	number	number	NOUN
cblr-2960	22	25	of	of	ADP
cblr-2960	22	26	funds	fund	NOUN
cblr-2960	22	27	.	.	PUNCT
cblr-2960	22	28	"	"	PUNCT
cblr-2960	23	1	franqois	franqois	PROPN
cblr-2960	23	2	-	-	PUNCT
cblr-2960	23	3	serge	serge	NOUN
cblr-2960	23	4	lhabitant	lhabitant	PROPN
cblr-2960	23	5	,	,	PUNCT
cblr-2960	23	6	handbook	handbook	NOUN
cblr-2960	23	7	of	of	ADP
cblr-2960	23	8	hedge	hedge	NOUN
cblr-2960	23	9	funds	fund	NOUN
cblr-2960	23	10	20	20	NUM
cblr-2960	23	11	(	(	PUNCT
cblr-2960	23	12	2006	2006	NUM
cblr-2960	23	13	)	)	PUNCT
cblr-2960	23	14	.	.	PUNCT
cblr-2960	24	1	although	although	SCONJ
cblr-2960	24	2	precise	precise	ADJ
cblr-2960	24	3	figures	figure	NOUN
cblr-2960	24	4	are	be	AUX
cblr-2960	24	5	difficult	difficult	ADJ
cblr-2960	24	6	to	to	PART
cblr-2960	24	7	obtain	obtain	VERB
cblr-2960	24	8	,	,	PUNCT
cblr-2960	24	9	recent	recent	ADJ
cblr-2960	24	10	industry	industry	NOUN
cblr-2960	24	11	reports	report	NOUN
cblr-2960	24	12	estimate	estimate	VERB
cblr-2960	24	13	hedge	hedge	NOUN
cblr-2960	24	14	funds	fund	NOUN
cblr-2960	24	15	manage	manage	VERB
cblr-2960	24	16	a	a	DET
cblr-2960	24	17	total	total	ADJ
cblr-2960	24	18	wealth	wealth	NOUN
cblr-2960	24	19	of	of	ADP
cblr-2960	24	20	more	more	ADJ
cblr-2960	24	21	than	than	ADP
cblr-2960	24	22	a	a	DET
cblr-2960	24	23	trillion	trillion	NUM
cblr-2960	24	24	dollars	dollar	NOUN
cblr-2960	24	25	,	,	PUNCT
cblr-2960	24	26	compared	compare	VERB
cblr-2960	24	27	to	to	ADP
cblr-2960	24	28	less	less	ADJ
cblr-2960	24	29	than	than	ADP
cblr-2960	24	30	$	$	SYM
cblr-2960	24	31	40	40	NUM
cblr-2960	24	32	billion	billion	NUM
cblr-2960	24	33	in	in	ADP
cblr-2960	24	34	1990	1990	NUM
cblr-2960	24	35	.	.	PUNCT
cblr-2960	25	1	i	i	PRON
cblr-2960	25	2	d.	d.	PROPN
cblr-2960	25	3	;	;	PUNCT
cblr-2960	25	4	see	see	VERB
cblr-2960	25	5	also	also	ADV
cblr-2960	25	6	daisy	daisy	PROPN
cblr-2960	25	7	maxey	maxey	PROPN
cblr-2960	25	8	,	,	PUNCT
cblr-2960	25	9	hedge	hedge	NOUN
cblr-2960	25	10	managers	manager	NOUN
cblr-2960	25	11	see	see	VERB
cblr-2960	25	12	consolidation	consolidation	NOUN
cblr-2960	25	13	coming	come	VERB
cblr-2960	25	14	,	,	PUNCT
cblr-2960	25	15	wall	wall	PROPN
cblr-2960	25	16	st	st	PROPN
cblr-2960	25	17	.	.	PROPN
cblr-2960	25	18	j.	j.	PROPN
cblr-2960	25	19	,	,	PUNCT
cblr-2960	25	20	sept	sept	PROPN
cblr-2960	25	21	.	.	PROPN
cblr-2960	25	22	10	10	NUM
cblr-2960	25	23	,	,	PUNCT
cblr-2960	25	24	2007	2007	NUM
cblr-2960	25	25	,	,	PUNCT
cblr-2960	25	26	at	at	ADP
cblr-2960	25	27	cll	cll	PROPN
cblr-2960	25	28	(	(	PUNCT
cblr-2960	25	29	noting	note	VERB
cblr-2960	25	30	that	that	SCONJ
cblr-2960	25	31	hedge	hedge	NOUN
cblr-2960	25	32	funds	fund	NOUN
cblr-2960	25	33	expect	expect	VERB
cblr-2960	25	34	to	to	PART
cblr-2960	25	35	keep	keep	VERB
cblr-2960	25	36	growing	grow	VERB
cblr-2960	25	37	)	)	PUNCT
cblr-2960	25	38	.	.	PUNCT
cblr-2960	26	1	2	2	NUM
cblr-2960	26	2	david	david	PROPN
cblr-2960	26	3	m.	m.	PROPN
cblr-2960	26	4	schizer	schizer	PROPN
cblr-2960	26	5	,	,	PUNCT
cblr-2960	26	6	balance	balance	NOUN
cblr-2960	26	7	in	in	ADP
cblr-2960	26	8	the	the	DET
cblr-2960	26	9	taxation	taxation	NOUN
cblr-2960	26	10	of	of	ADP
cblr-2960	26	11	derivative	derivative	ADJ
cblr-2960	26	12	securities	security	NOUN
cblr-2960	26	13	:	:	PUNCT
cblr-2960	26	14	an	an	DET
cblr-2960	26	15	agenda	agenda	NOUN
cblr-2960	26	16	for	for	ADP
cblr-2960	26	17	reform	reform	NOUN
cblr-2960	26	18	,	,	PUNCT
cblr-2960	26	19	104	104	NUM
cblr-2960	26	20	colum	colum	NOUN
cblr-2960	26	21	.	.	PUNCT
cblr-2960	27	1	l.	l.	PROPN
cblr-2960	27	2	rev	rev	PROPN
cblr-2960	27	3	.	.	PROPN
cblr-2960	27	4	1886	1886	NUM
cblr-2960	27	5	,	,	PUNCT
cblr-2960	27	6	1935	1935	NUM
cblr-2960	27	7	(	(	PUNCT
cblr-2960	27	8	2004	2004	NUM
cblr-2960	27	9	)	)	PUNCT
cblr-2960	27	10	;	;	PUNCT
cblr-2960	27	11	i.r.c	i.r.c	NOUN
cblr-2960	27	12	.	.	PUNCT
cblr-2960	28	1	§	§	PROPN
cblr-2960	28	2	1	1	NUM
cblr-2960	28	3	(	(	PUNCT
cblr-2960	28	4	short	short	ADJ
cblr-2960	28	5	term	term	NOUN
cblr-2960	28	6	gains	gain	NOUN
cblr-2960	28	7	are	be	AUX
cblr-2960	28	8	taxed	tax	VERB
cblr-2960	28	9	as	as	ADP
cblr-2960	28	10	ordinary	ordinary	ADJ
cblr-2960	28	11	income	income	NOUN
cblr-2960	28	12	;	;	PUNCT
cblr-2960	28	13	the	the	DET
cblr-2960	28	14	applicable	applicable	ADJ
cblr-2960	28	15	tax	tax	NOUN
cblr-2960	28	16	rate	rate	NOUN
cblr-2960	28	17	for	for	ADP
cblr-2960	28	18	taxpayers	taxpayer	NOUN
cblr-2960	28	19	in	in	ADP
cblr-2960	28	20	the	the	DET
cblr-2960	28	21	highest	high	ADJ
cblr-2960	28	22	tax	tax	NOUN
cblr-2960	28	23	bracket	bracket	NOUN
cblr-2960	28	24	is	be	AUX
cblr-2960	28	25	35	35	NUM
cblr-2960	28	26	%	%	NOUN
cblr-2960	28	27	)	)	PUNCT
cblr-2960	28	28	.	.	PUNCT
cblr-2960	29	1	3	3	NUM
cblr-2960	29	2	charlene	charlene	PROPN
cblr-2960	29	3	d.	d.	PROPN
cblr-2960	29	4	luke	luke	PROPN
cblr-2960	29	5	,	,	PUNCT
cblr-2960	29	6	beating	beat	VERB
cblr-2960	29	7	the	the	DET
cblr-2960	29	8	"	"	PUNCT
cblr-2960	29	9	wrap	wrap	NOUN
cblr-2960	29	10	"	"	PUNCT
cblr-2960	29	11	the	the	DET
cblr-2960	29	12	agency	agency	NOUN
cblr-2960	29	13	effort	effort	NOUN
cblr-2960	29	14	to	to	PART
cblr-2960	29	15	control	control	VERB
cblr-2960	29	16	wraparound	wraparound	NOUN
cblr-2960	29	17	insurance	insurance	NOUN
cblr-2960	29	18	tax	tax	NOUN
cblr-2960	29	19	shelters	shelter	NOUN
cblr-2960	29	20	,	,	PUNCT
cblr-2960	29	21	25	25	NUM
cblr-2960	29	22	va	va	NOUN
cblr-2960	29	23	.	.	PUNCT
cblr-2960	29	24	tax	tax	PROPN
cblr-2960	29	25	rev	rev	PROPN
cblr-2960	29	26	.	.	PROPN
cblr-2960	29	27	129	129	NUM
cblr-2960	29	28	,	,	PUNCT
cblr-2960	29	29	132	132	NUM
cblr-2960	29	30	(	(	PUNCT
cblr-2960	29	31	2005	2005	NUM
cblr-2960	29	32	)	)	PUNCT
cblr-2960	29	33	(	(	PUNCT
cblr-2960	29	34	explaining	explain	VERB
cblr-2960	29	35	that	that	SCONJ
cblr-2960	29	36	life	life	NOUN
cblr-2960	29	37	insurance	insurance	NOUN
cblr-2960	29	38	wrappers	wrapper	NOUN
cblr-2960	29	39	were	be	AUX
cblr-2960	29	40	used	use	VERB
cblr-2960	29	41	primarily	primarily	ADV
cblr-2960	29	42	to	to	PART
cblr-2960	29	43	convert	convert	VERB
cblr-2960	29	44	ordinary	ordinary	ADJ
cblr-2960	29	45	income	income	NOUN
cblr-2960	29	46	into	into	ADP
cblr-2960	29	47	tax	tax	NOUN
cblr-2960	29	48	-	-	PUNCT
cblr-2960	29	49	sheltered	shelter	VERB
cblr-2960	29	50	income	income	NOUN
cblr-2960	29	51	)	)	PUNCT
cblr-2960	29	52	.	.	PUNCT
cblr-2960	30	1	4	4	NUM
cblr-2960	30	2	grant	grant	PROPN
cblr-2960	30	3	r.	r.	PROPN
cblr-2960	30	4	markuson	markuson	PROPN
cblr-2960	30	5	,	,	PUNCT
cblr-2960	30	6	private	private	ADJ
cblr-2960	30	7	placement	placement	NOUN
cblr-2960	30	8	life	life	NOUN
cblr-2960	30	9	insurance	insurance	NOUN
cblr-2960	30	10	:	:	PUNCT
cblr-2960	30	11	new	new	ADJ
cblr-2960	30	12	insights	insight	NOUN
cblr-2960	30	13	for	for	ADP
cblr-2960	30	14	an	an	DET
cblr-2960	30	15	enduring	endure	VERB
cblr-2960	30	16	technique	technique	NOUN
cblr-2960	30	17	1	1	NUM
cblr-2960	30	18	(	(	PUNCT
cblr-2960	30	19	2002	2002	NUM
cblr-2960	30	20	)	)	PUNCT
cblr-2960	30	21	,	,	PUNCT
cblr-2960	30	22	available	available	ADJ
cblr-2960	30	23	at	at	ADP
cblr-2960	30	24	http://www.mnlaw.com/t&egrant.pdf	http://www.mnlaw.com/t&egrant.pdf	PROPN
cblr-2960	30	25	.	.	PUNCT
cblr-2960	31	1	5	5	NUM
cblr-2960	31	2	see	see	VERB
cblr-2960	31	3	infra	infra	NOUN
cblr-2960	31	4	part	part	PROPN
cblr-2960	31	5	ii	ii	PROPN
cblr-2960	31	6	.	.	PROPN
cblr-2960	31	7	6	6	NUM
cblr-2960	31	8	rachel	rachel	PROPN
cblr-2960	31	9	e.	e.	PROPN
cblr-2960	31	10	silverman	silverman	PROPN
cblr-2960	31	11	,	,	PUNCT
cblr-2960	31	12	the	the	DET
cblr-2960	31	13	search	search	NOUN
cblr-2960	31	14	for	for	ADP
cblr-2960	31	15	a	a	DET
cblr-2960	31	16	safe	safe	ADJ
cblr-2960	31	17	tax	tax	NOUN
cblr-2960	31	18	shelter	shelter	NOUN
cblr-2960	31	19	as	as	SCONJ
cblr-2960	31	20	irs	irs	PROPN
cblr-2960	31	21	steps	step	VERB
cblr-2960	31	22	up	up	ADP
cblr-2960	31	23	scrutiny	scrutiny	NOUN
cblr-2960	31	24	,	,	PUNCT
cblr-2960	31	25	advisers	adviser	NOUN
cblr-2960	31	26	shift	shift	VERB
cblr-2960	31	27	to	to	ADP
cblr-2960	31	28	conservative	conservative	ADJ
cblr-2960	31	29	tactics	tactic	NOUN
cblr-2960	31	30	,	,	PUNCT
cblr-2960	31	31	but	but	CCONJ
cblr-2960	31	32	some	some	DET
cblr-2960	31	33	still	still	ADV
cblr-2960	31	34	test	test	NOUN
cblr-2960	31	35	limits	limit	NOUN
cblr-2960	31	36	,	,	PUNCT
cblr-2960	31	37	wall	wall	PROPN
cblr-2960	31	38	st	st	PROPN
cblr-2960	31	39	.	.	PROPN
cblr-2960	31	40	j.	j.	PROPN
cblr-2960	31	41	,	,	PUNCT
cblr-2960	31	42	oct	oct	PROPN
cblr-2960	31	43	.	.	PROPN
cblr-2960	31	44	13	13	NUM
cblr-2960	31	45	,	,	PUNCT
cblr-2960	31	46	2005	2005	NUM
cblr-2960	31	47	,	,	PUNCT
cblr-2960	31	48	at	at	ADP
cblr-2960	31	49	d1	d1	PROPN
cblr-2960	31	50	(	(	PUNCT
cblr-2960	31	51	"	"	PUNCT
cblr-2960	31	52	assets	asset	NOUN
cblr-2960	31	53	inside	inside	ADP
cblr-2960	31	54	a	a	DET
cblr-2960	31	55	life	life	NOUN
cblr-2960	31	56	insurance	insurance	NOUN
cblr-2960	31	57	policy	policy	NOUN
cblr-2960	31	58	can	can	AUX
cblr-2960	31	59	grow	grow	VERB
cblr-2960	31	60	tax	tax	NOUN
cblr-2960	31	61	-	-	PUNCT
cblr-2960	31	62	free	free	ADJ
cblr-2960	31	63	....	....	PUNCT
cblr-2960	31	64	"	"	PUNCT
cblr-2960	31	65	)	)	PUNCT
cblr-2960	31	66	.	.	PUNCT
cblr-2960	32	1	no	no	INTJ
cblr-2960	32	2	.	.	PUNCT
cblr-2960	33	1	2:694	2:694	NUM
cblr-2960	33	2	]	]	X
cblr-2960	33	3	job	job	NOUN
cblr-2960	33	4	well	well	ADV
cblr-2960	33	5	done	do	VERB
cblr-2960	33	6	columbia	columbia	PROPN
cblr-2960	33	7	business	business	NOUN
cblr-2960	33	8	law	law	PROPN
cblr-2960	33	9	review	review	VERB
cblr-2960	33	10	borrowing	borrowing	NOUN
cblr-2960	33	11	funds	fund	NOUN
cblr-2960	33	12	from	from	ADP
cblr-2960	33	13	the	the	DET
cblr-2960	33	14	policy	policy	NOUN
cblr-2960	33	15	,	,	PUNCT
cblr-2960	33	16	tax	tax	NOUN
cblr-2960	33	17	-	-	PUNCT
cblr-2960	33	18	free.7	free.7	NOUN
cblr-2960	33	19	while	while	SCONJ
cblr-2960	33	20	the	the	DET
cblr-2960	33	21	use	use	NOUN
cblr-2960	33	22	of	of	ADP
cblr-2960	33	23	private	private	ADJ
cblr-2960	33	24	placement	placement	NOUN
cblr-2960	33	25	life	life	NOUN
cblr-2960	33	26	insurance	insurance	NOUN
cblr-2960	33	27	contracts	contract	NOUN
cblr-2960	33	28	gives	give	VERB
cblr-2960	33	29	wealthy	wealthy	ADJ
cblr-2960	33	30	investors	investor	NOUN
cblr-2960	33	31	the	the	DET
cblr-2960	33	32	prospect	prospect	NOUN
cblr-2960	33	33	of	of	ADP
cblr-2960	33	34	huge	huge	ADJ
cblr-2960	33	35	tax	tax	NOUN
cblr-2960	33	36	savings	saving	NOUN
cblr-2960	33	37	on	on	ADP
cblr-2960	33	38	hedge	hedge	NOUN
cblr-2960	33	39	fund	fund	NOUN
cblr-2960	33	40	investments	investment	NOUN
cblr-2960	33	41	,	,	PUNCT
cblr-2960	33	42	the	the	DET
cblr-2960	33	43	transaction	transaction	NOUN
cblr-2960	33	44	also	also	ADV
cblr-2960	33	45	gives	give	VERB
cblr-2960	33	46	rise	rise	NOUN
cblr-2960	33	47	to	to	ADP
cblr-2960	33	48	the	the	DET
cblr-2960	33	49	question	question	NOUN
cblr-2960	33	50	of	of	ADP
cblr-2960	33	51	whether	whether	SCONJ
cblr-2960	33	52	the	the	DET
cblr-2960	33	53	practice	practice	NOUN
cblr-2960	33	54	is	be	AUX
cblr-2960	33	55	a	a	DET
cblr-2960	33	56	bona	bona	ADJ
cblr-2960	33	57	fide	fide	ADJ
cblr-2960	33	58	tax	tax	NOUN
cblr-2960	33	59	planning	planning	NOUN
cblr-2960	33	60	device	device	NOUN
cblr-2960	33	61	or	or	CCONJ
cblr-2960	33	62	an	an	DET
cblr-2960	33	63	improper	improper	ADJ
cblr-2960	33	64	tax	tax	NOUN
cblr-2960	33	65	shelter	shelter	NOUN
cblr-2960	33	66	.	.	PUNCT
cblr-2960	34	1	under	under	ADP
cblr-2960	34	2	current	current	ADJ
cblr-2960	34	3	law	law	NOUN
cblr-2960	34	4	,	,	PUNCT
cblr-2960	34	5	taxpayers	taxpayer	NOUN
cblr-2960	34	6	are	be	AUX
cblr-2960	34	7	able	able	ADJ
cblr-2960	34	8	to	to	PART
cblr-2960	34	9	take	take	VERB
cblr-2960	34	10	advantage	advantage	NOUN
cblr-2960	34	11	of	of	ADP
cblr-2960	34	12	inconsistencies	inconsistency	NOUN
cblr-2960	34	13	or	or	CCONJ
cblr-2960	34	14	gaps	gap	NOUN
cblr-2960	34	15	in	in	ADP
cblr-2960	34	16	the	the	DET
cblr-2960	34	17	tax	tax	NOUN
cblr-2960	34	18	rules	rule	NOUN
cblr-2960	34	19	to	to	PART
cblr-2960	34	20	reduce	reduce	VERB
cblr-2960	34	21	their	their	PRON
cblr-2960	34	22	tax	tax	NOUN
cblr-2960	34	23	liabilities.8	liabilities.8	PROPN
cblr-2960	34	24	however	however	ADV
cblr-2960	34	25	,	,	PUNCT
cblr-2960	34	26	there	there	PRON
cblr-2960	34	27	is	be	VERB
cblr-2960	34	28	often	often	ADV
cblr-2960	34	29	a	a	DET
cblr-2960	34	30	blurry	blurry	ADJ
cblr-2960	34	31	line	line	NOUN
cblr-2960	34	32	between	between	ADP
cblr-2960	34	33	an	an	DET
cblr-2960	34	34	improper	improper	ADJ
cblr-2960	34	35	tax	tax	NOUN
cblr-2960	34	36	shelter	shelter	NOUN
cblr-2960	34	37	and	and	CCONJ
cblr-2960	34	38	more	more	ADV
cblr-2960	34	39	legitimate	legitimate	ADJ
cblr-2960	34	40	strategies	strategy	NOUN
cblr-2960	34	41	that	that	PRON
cblr-2960	34	42	take	take	VERB
cblr-2960	34	43	advantage	advantage	NOUN
cblr-2960	34	44	of	of	ADP
cblr-2960	34	45	the	the	DET
cblr-2960	34	46	intricacies	intricacy	NOUN
cblr-2960	34	47	of	of	ADP
cblr-2960	34	48	the	the	DET
cblr-2960	34	49	tax	tax	NOUN
cblr-2960	34	50	code.9	code.9	PROPN
cblr-2960	34	51	improper	improper	ADJ
cblr-2960	34	52	tax	tax	NOUN
cblr-2960	34	53	shelters	shelter	NOUN
cblr-2960	34	54	arise	arise	VERB
cblr-2960	34	55	because	because	SCONJ
cblr-2960	34	56	of	of	ADP
cblr-2960	34	57	the	the	DET
cblr-2960	34	58	difficulty	difficulty	NOUN
cblr-2960	34	59	in	in	ADP
cblr-2960	34	60	perfectly	perfectly	ADV
cblr-2960	34	61	specifying	specify	VERB
cblr-2960	34	62	or	or	CCONJ
cblr-2960	34	63	defining	define	VERB
cblr-2960	34	64	the	the	DET
cblr-2960	34	65	tax	tax	NOUN
cblr-2960	34	66	base	base	NOUN
cblr-2960	34	67	.	.	PUNCT
cblr-2960	35	1	10	10	NUM
cblr-2960	35	2	through	through	ADP
cblr-2960	35	3	revenue	revenue	NOUN
cblr-2960	35	4	rulings	ruling	NOUN
cblr-2960	35	5	,	,	PUNCT
cblr-2960	35	6	private	private	ADJ
cblr-2960	35	7	letter	letter	NOUN
cblr-2960	35	8	rulings	ruling	NOUN
cblr-2960	35	9	,	,	PUNCT
cblr-2960	35	10	and	and	CCONJ
cblr-2960	35	11	treasury	treasury	PROPN
cblr-2960	35	12	regulations	regulation	NOUN
cblr-2960	35	13	,	,	PUNCT
cblr-2960	35	14	the	the	DET
cblr-2960	35	15	treasury	treasury	PROPN
cblr-2960	35	16	department	department	PROPN
cblr-2960	35	17	and	and	CCONJ
cblr-2960	35	18	the	the	DET
cblr-2960	35	19	internal	internal	ADJ
cblr-2960	35	20	revenue	revenue	NOUN
cblr-2960	35	21	service	service	NOUN
cblr-2960	35	22	(	(	PUNCT
cblr-2960	35	23	"	"	PUNCT
cblr-2960	35	24	irs	irs	PROPN
cblr-2960	35	25	"	"	PUNCT
cblr-2960	35	26	or	or	CCONJ
cblr-2960	35	27	"	"	PUNCT
cblr-2960	35	28	service	service	NOUN
cblr-2960	35	29	"	"	PUNCT
cblr-2960	35	30	)	)	PUNCT
cblr-2960	35	31	convey	convey	VERB
cblr-2960	35	32	their	their	PRON
cblr-2960	35	33	position	position	NOUN
cblr-2960	35	34	and	and	CCONJ
cblr-2960	35	35	offer	offer	VERB
cblr-2960	35	36	guidance	guidance	NOUN
cblr-2960	35	37	to	to	ADP
cblr-2960	35	38	practitioners	practitioner	NOUN
cblr-2960	35	39	and	and	CCONJ
cblr-2960	35	40	taxpayers	taxpayer	NOUN
cblr-2960	35	41	regarding	regard	VERB
cblr-2960	35	42	the	the	DET
cblr-2960	35	43	relevant	relevant	ADJ
cblr-2960	35	44	transaction	transaction	NOUN
cblr-2960	35	45	.	.	PUNCT
cblr-2960	35	46	"	"	PUNCT
cblr-2960	36	1	this	this	DET
cblr-2960	36	2	note	note	NOUN
cblr-2960	36	3	analyzes	analyze	VERB
cblr-2960	36	4	the	the	DET
cblr-2960	36	5	effectiveness	effectiveness	NOUN
cblr-2960	36	6	of	of	ADP
cblr-2960	36	7	these	these	DET
cblr-2960	36	8	rulings	ruling	NOUN
cblr-2960	36	9	and	and	CCONJ
cblr-2960	36	10	regulations	regulation	NOUN
cblr-2960	36	11	in	in	ADP
cblr-2960	36	12	the	the	DET
cblr-2960	36	13	context	context	NOUN
cblr-2960	36	14	of	of	ADP
cblr-2960	36	15	private	private	ADJ
cblr-2960	36	16	placement	placement	NOUN
cblr-2960	36	17	life	life	NOUN
cblr-2960	36	18	insurance	insurance	NOUN
cblr-2960	36	19	wrappers	wrapper	NOUN
cblr-2960	36	20	.	.	PUNCT
cblr-2960	37	1	ultimately	ultimately	ADV
cblr-2960	37	2	,	,	PUNCT
cblr-2960	37	3	the	the	DET
cblr-2960	37	4	rulings	ruling	NOUN
cblr-2960	37	5	and	and	CCONJ
cblr-2960	37	6	regulations	regulation	NOUN
cblr-2960	37	7	have	have	AUX
cblr-2960	37	8	succeeded	succeed	VERB
cblr-2960	37	9	in	in	ADP
cblr-2960	37	10	preventing	prevent	VERB
cblr-2960	37	11	the	the	DET
cblr-2960	37	12	use	use	NOUN
cblr-2960	37	13	of	of	ADP
cblr-2960	37	14	life	life	NOUN
cblr-2960	37	15	'	'	PART
cblr-2960	37	16	allison	allison	PROPN
cblr-2960	37	17	b.	b.	PROPN
cblr-2960	37	18	colter	colter	PROPN
cblr-2960	37	19	,	,	PUNCT
cblr-2960	37	20	insurers	insurer	NOUN
cblr-2960	37	21	provide	provide	VERB
cblr-2960	37	22	investors	investor	NOUN
cblr-2960	37	23	access	access	NOUN
cblr-2960	37	24	to	to	ADP
cblr-2960	37	25	hedge	hedge	NOUN
cblr-2960	37	26	funds	fund	NOUN
cblr-2960	37	27	,	,	PUNCT
cblr-2960	37	28	wall	wall	PROPN
cblr-2960	37	29	st	st	PROPN
cblr-2960	37	30	.	.	PROPN
cblr-2960	37	31	j.	j.	PROPN
cblr-2960	37	32	,	,	PUNCT
cblr-2960	37	33	oct	oct	PROPN
cblr-2960	37	34	.	.	PROPN
cblr-2960	37	35	2	2	NUM
cblr-2960	37	36	,	,	PUNCT
cblr-2960	37	37	2001	2001	NUM
cblr-2960	37	38	,	,	PUNCT
cblr-2960	37	39	at	at	ADP
cblr-2960	37	40	b7	b7	PROPN
cblr-2960	37	41	.	.	PUNCT
cblr-2960	37	42	'	'	PUNCT
cblr-2960	38	1	david	david	PROPN
cblr-2960	38	2	a.	a.	PROPN
cblr-2960	38	3	weisbach	weisbach	PROPN
cblr-2960	38	4	,	,	PUNCT
cblr-2960	38	5	an	an	DET
cblr-2960	38	6	economic	economic	ADJ
cblr-2960	38	7	analysis	analysis	NOUN
cblr-2960	38	8	of	of	ADP
cblr-2960	38	9	anti	anti	ADJ
cblr-2960	38	10	-	-	ADJ
cblr-2960	38	11	tax	tax	ADJ
cblr-2960	38	12	-	-	PUNCT
cblr-2960	38	13	avoidance	avoidance	NOUN
cblr-2960	38	14	doctrines	doctrine	NOUN
cblr-2960	38	15	,	,	PUNCT
cblr-2960	38	16	4	4	NUM
cblr-2960	38	17	am	am	NOUN
cblr-2960	38	18	.	.	PUNCT
cblr-2960	39	1	l.	l.	PROPN
cblr-2960	39	2	&	&	CCONJ
cblr-2960	39	3	econ	econ	PROPN
cblr-2960	39	4	.	.	PUNCT
cblr-2960	40	1	rev	rev	PROPN
cblr-2960	40	2	.	.	PROPN
cblr-2960	40	3	88	88	NUM
cblr-2960	40	4	,	,	PUNCT
cblr-2960	40	5	89	89	NUM
cblr-2960	40	6	(	(	PUNCT
cblr-2960	40	7	2002	2002	NUM
cblr-2960	40	8	)	)	PUNCT
cblr-2960	40	9	(	(	PUNCT
cblr-2960	40	10	noting	note	VERB
cblr-2960	40	11	that	that	SCONJ
cblr-2960	40	12	"	"	PUNCT
cblr-2960	40	13	taxpayers	taxpayer	NOUN
cblr-2960	40	14	have	have	VERB
cblr-2960	40	15	what	what	PRON
cblr-2960	40	16	is	be	AUX
cblr-2960	40	17	termed	term	VERB
cblr-2960	40	18	a	a	DET
cblr-2960	40	19	'	'	PUNCT
cblr-2960	40	20	right	right	NOUN
cblr-2960	40	21	'	'	PUNCT
cblr-2960	40	22	to	to	PART
cblr-2960	40	23	alter	alter	VERB
cblr-2960	40	24	their	their	PRON
cblr-2960	40	25	affairs	affair	NOUN
cblr-2960	40	26	to	to	PART
cblr-2960	40	27	minimize	minimize	VERB
cblr-2960	40	28	taxes	taxis	NOUN
cblr-2960	40	29	"	"	PUNCT
cblr-2960	40	30	)	)	PUNCT
cblr-2960	40	31	.	.	PUNCT
cblr-2960	40	32	'	'	PUNCT
cblr-2960	41	1	see	see	VERB
cblr-2960	41	2	generally	generally	ADV
cblr-2960	41	3	silverman	silverman	NOUN
cblr-2960	41	4	,	,	PUNCT
cblr-2960	41	5	supra	supra	PROPN
cblr-2960	41	6	note	note	PROPN
cblr-2960	41	7	6	6	NUM
cblr-2960	41	8	(	(	PUNCT
cblr-2960	41	9	comparing	compare	VERB
cblr-2960	41	10	legitimate	legitimate	ADJ
cblr-2960	41	11	strategies	strategy	NOUN
cblr-2960	41	12	that	that	PRON
cblr-2960	41	13	are	be	AUX
cblr-2960	41	14	composed	compose	VERB
cblr-2960	41	15	of	of	ADP
cblr-2960	41	16	"	"	PUNCT
cblr-2960	41	17	well	well	ADV
cblr-2960	41	18	-	-	PUNCT
cblr-2960	41	19	established	establish	VERB
cblr-2960	41	20	,	,	PUNCT
cblr-2960	41	21	legal	legal	ADJ
cblr-2960	41	22	building	building	NOUN
cblr-2960	41	23	blocks	block	NOUN
cblr-2960	41	24	"	"	PUNCT
cblr-2960	41	25	with	with	ADP
cblr-2960	41	26	strategies	strategy	NOUN
cblr-2960	41	27	that	that	PRON
cblr-2960	41	28	lack	lack	VERB
cblr-2960	41	29	any	any	DET
cblr-2960	41	30	real	real	ADJ
cblr-2960	41	31	economic	economic	ADJ
cblr-2960	41	32	purpose	purpose	NOUN
cblr-2960	41	33	other	other	ADJ
cblr-2960	41	34	than	than	SCONJ
cblr-2960	41	35	to	to	PART
cblr-2960	41	36	avoid	avoid	VERB
cblr-2960	41	37	taxes	taxis	NOUN
cblr-2960	41	38	)	)	PUNCT
cblr-2960	41	39	.	.	PUNCT
cblr-2960	42	1	10	10	NUM
cblr-2960	42	2	see	see	VERB
cblr-2960	42	3	weisbach	weisbach	NOUN
cblr-2960	42	4	,	,	PUNCT
cblr-2960	42	5	supra	supra	ADJ
cblr-2960	42	6	note	note	NOUN
cblr-2960	42	7	8	8	NUM
cblr-2960	42	8	,	,	PUNCT
cblr-2960	42	9	at	at	ADP
cblr-2960	42	10	93	93	NUM
cblr-2960	42	11	(	(	PUNCT
cblr-2960	42	12	explaining	explain	VERB
cblr-2960	42	13	that	that	SCONJ
cblr-2960	42	14	tax	tax	NOUN
cblr-2960	42	15	shelters	shelter	NOUN
cblr-2960	42	16	are	be	AUX
cblr-2960	42	17	effectively	effectively	ADV
cblr-2960	42	18	"	"	PUNCT
cblr-2960	42	19	inadvertent	inadvertent	ADJ
cblr-2960	42	20	omissions	omission	NOUN
cblr-2960	42	21	from	from	ADP
cblr-2960	42	22	the	the	DET
cblr-2960	42	23	tax	tax	NOUN
cblr-2960	42	24	base	base	NOUN
cblr-2960	42	25	"	"	PUNCT
cblr-2960	42	26	)	)	PUNCT
cblr-2960	42	27	.	.	PUNCT
cblr-2960	43	1	the	the	DET
cblr-2960	43	2	tax	tax	NOUN
cblr-2960	43	3	base	base	NOUN
cblr-2960	43	4	is	be	AUX
cblr-2960	43	5	the	the	DET
cblr-2960	43	6	total	total	ADJ
cblr-2960	43	7	amount	amount	NOUN
cblr-2960	43	8	to	to	PART
cblr-2960	43	9	which	which	PRON
cblr-2960	43	10	the	the	DET
cblr-2960	43	11	appropriate	appropriate	ADJ
cblr-2960	43	12	tax	tax	NOUN
cblr-2960	43	13	rate	rate	NOUN
cblr-2960	43	14	is	be	AUX
cblr-2960	43	15	applied	apply	VERB
cblr-2960	43	16	.	.	PUNCT
cblr-2960	44	1	william	william	PROPN
cblr-2960	44	2	a.	a.	PROPN
cblr-2960	44	3	klein	klein	PROPN
cblr-2960	44	4	etal	etal	PROPN
cblr-2960	44	5	.	.	PUNCT
cblr-2960	44	6	,	,	PUNCT
cblr-2960	44	7	federal	federal	ADJ
cblr-2960	44	8	income	income	NOUN
cblr-2960	44	9	taxation	taxation	NOUN
cblr-2960	44	10	22	22	NUM
cblr-2960	44	11	(	(	PUNCT
cblr-2960	44	12	14th	14th	NOUN
cblr-2960	44	13	ed	ed	NOUN
cblr-2960	44	14	.	.	PUNCT
cblr-2960	44	15	2006	2006	NUM
cblr-2960	44	16	)	)	PUNCT
cblr-2960	44	17	.	.	PUNCT
cblr-2960	45	1	1	1	NUM
cblr-2960	45	2	see	see	VERB
cblr-2960	45	3	rachel	rachel	PROPN
cblr-2960	45	4	e.	e.	PROPN
cblr-2960	45	5	silverman	silverman	PROPN
cblr-2960	45	6	,	,	PUNCT
cblr-2960	45	7	insuring	insure	VERB
cblr-2960	45	8	against	against	ADP
cblr-2960	45	9	hedge	hedge	NOUN
cblr-2960	45	10	-	-	PUNCT
cblr-2960	45	11	fund	fund	NOUN
cblr-2960	45	12	taxes	taxis	NOUN
cblr-2960	45	13	'	'	PART
cblr-2960	45	14	private	private	ADJ
cblr-2960	45	15	placement	placement	NOUN
cblr-2960	45	16	'	'	PUNCT
cblr-2960	45	17	policies	policy	NOUN
cblr-2960	45	18	draw	draw	VERB
cblr-2960	45	19	more	more	ADV
cblr-2960	45	20	wealthy	wealthy	ADJ
cblr-2960	45	21	investors	investor	NOUN
cblr-2960	45	22	despite	despite	SCONJ
cblr-2960	45	23	fees	fee	NOUN
cblr-2960	45	24	,	,	PUNCT
cblr-2960	45	25	limited	limited	ADJ
cblr-2960	45	26	control	control	NOUN
cblr-2960	45	27	,	,	PUNCT
cblr-2960	45	28	wall	wall	PROPN
cblr-2960	45	29	st	st	PROPN
cblr-2960	45	30	.	.	PROPN
cblr-2960	45	31	j.	j.	PROPN
cblr-2960	45	32	,	,	PUNCT
cblr-2960	45	33	oct	oct	PROPN
cblr-2960	45	34	.	.	PROPN
cblr-2960	45	35	18	18	NUM
cblr-2960	45	36	,	,	PUNCT
cblr-2960	45	37	2006	2006	NUM
cblr-2960	45	38	,	,	PUNCT
cblr-2960	45	39	at	at	ADP
cblr-2960	45	40	d1	d1	PROPN
cblr-2960	45	41	(	(	PUNCT
cblr-2960	45	42	explaining	explain	VERB
cblr-2960	45	43	how	how	SCONJ
cblr-2960	45	44	recent	recent	ADJ
cblr-2960	45	45	rulings	ruling	NOUN
cblr-2960	45	46	and	and	CCONJ
cblr-2960	45	47	regulations	regulation	NOUN
cblr-2960	45	48	have	have	AUX
cblr-2960	45	49	laid	lay	VERB
cblr-2960	45	50	out	out	ADP
cblr-2960	45	51	more	more	ADV
cblr-2960	45	52	clearly	clearly	ADV
cblr-2960	45	53	what	what	PRON
cblr-2960	45	54	is	be	AUX
cblr-2960	45	55	allowable	allowable	ADJ
cblr-2960	45	56	in	in	ADP
cblr-2960	45	57	private	private	ADJ
cblr-2960	45	58	placement	placement	NOUN
cblr-2960	45	59	life	life	NOUN
cblr-2960	45	60	insurance	insurance	NOUN
cblr-2960	45	61	,	,	PUNCT
cblr-2960	45	62	which	which	PRON
cblr-2960	45	63	in	in	ADP
cblr-2960	45	64	turn	turn	NOUN
cblr-2960	45	65	,	,	PUNCT
cblr-2960	45	66	has	have	AUX
cblr-2960	45	67	removed	remove	VERB
cblr-2960	45	68	uncertainty	uncertainty	NOUN
cblr-2960	45	69	among	among	ADP
cblr-2960	45	70	insurers	insurer	NOUN
cblr-2960	45	71	and	and	CCONJ
cblr-2960	45	72	investors	investor	NOUN
cblr-2960	45	73	)	)	PUNCT
cblr-2960	45	74	.	.	PUNCT
cblr-2960	46	1	[	[	X
cblr-2960	46	2	vol	vol	NOUN
cblr-2960	46	3	.	.	NOUN
cblr-2960	46	4	2008	2008	NUM
cblr-2960	46	5	job	job	NOUN
cblr-2960	46	6	well	well	ADV
cblr-2960	46	7	done	do	VERB
cblr-2960	46	8	insurance	insurance	NOUN
cblr-2960	46	9	as	as	ADP
cblr-2960	46	10	a	a	DET
cblr-2960	46	11	tax	tax	NOUN
cblr-2960	46	12	shelter	shelter	NOUN
cblr-2960	46	13	for	for	ADP
cblr-2960	46	14	hedge	hedge	NOUN
cblr-2960	46	15	fund	fund	NOUN
cblr-2960	46	16	investments	investment	NOUN
cblr-2960	46	17	,	,	PUNCT
cblr-2960	46	18	leaving	leave	VERB
cblr-2960	46	19	no	no	DET
cblr-2960	46	20	cause	cause	NOUN
cblr-2960	46	21	for	for	ADP
cblr-2960	46	22	congressional	congressional	ADJ
cblr-2960	46	23	concern	concern	NOUN
cblr-2960	46	24	today	today	NOUN
cblr-2960	46	25	.	.	PUNCT
cblr-2960	47	1	part	part	PROPN
cblr-2960	47	2	ii	ii	PROPN
cblr-2960	47	3	introduces	introduce	VERB
cblr-2960	47	4	private	private	ADJ
cblr-2960	47	5	placement	placement	NOUN
cblr-2960	47	6	life	life	NOUN
cblr-2960	47	7	insurance	insurance	NOUN
cblr-2960	47	8	contracts	contract	NOUN
cblr-2960	47	9	and	and	CCONJ
cblr-2960	47	10	explains	explain	VERB
cblr-2960	47	11	how	how	SCONJ
cblr-2960	47	12	they	they	PRON
cblr-2960	47	13	are	be	AUX
cblr-2960	47	14	used	use	VERB
cblr-2960	47	15	to	to	PART
cblr-2960	47	16	invest	invest	VERB
cblr-2960	47	17	in	in	ADP
cblr-2960	47	18	hedge	hedge	NOUN
cblr-2960	47	19	funds	fund	NOUN
cblr-2960	47	20	.	.	PUNCT
cblr-2960	48	1	part	part	NOUN
cblr-2960	48	2	iii	iii	PROPN
cblr-2960	48	3	delineates	delineate	VERB
cblr-2960	48	4	the	the	DET
cblr-2960	48	5	current	current	ADJ
cblr-2960	48	6	law	law	NOUN
cblr-2960	48	7	restricting	restrict	VERB
cblr-2960	48	8	private	private	ADJ
cblr-2960	48	9	placement	placement	NOUN
cblr-2960	48	10	life	life	NOUN
cblr-2960	48	11	insurance	insurance	NOUN
cblr-2960	48	12	policies	policy	NOUN
cblr-2960	48	13	and	and	CCONJ
cblr-2960	48	14	the	the	DET
cblr-2960	48	15	tax	tax	NOUN
cblr-2960	48	16	agencies	agency	NOUN
cblr-2960	48	17	'	'	PART
cblr-2960	48	18	most	most	ADV
cblr-2960	48	19	recent	recent	ADJ
cblr-2960	48	20	reform	reform	NOUN
cblr-2960	48	21	efforts	effort	NOUN
cblr-2960	48	22	to	to	PART
cblr-2960	48	23	curb	curb	VERB
cblr-2960	48	24	the	the	DET
cblr-2960	48	25	use	use	NOUN
cblr-2960	48	26	of	of	ADP
cblr-2960	48	27	hedge	hedge	NOUN
cblr-2960	48	28	funds	fund	NOUN
cblr-2960	48	29	in	in	ADP
cblr-2960	48	30	life	life	NOUN
cblr-2960	48	31	insurance	insurance	NOUN
cblr-2960	48	32	wrappers	wrapper	NOUN
cblr-2960	48	33	.	.	PUNCT
cblr-2960	49	1	part	part	NOUN
cblr-2960	49	2	iv	iv	NUM
cblr-2960	49	3	outlines	outline	VERB
cblr-2960	49	4	two	two	NUM
cblr-2960	49	5	methods	method	NOUN
cblr-2960	49	6	for	for	ADP
cblr-2960	49	7	analyzing	analyze	VERB
cblr-2960	49	8	the	the	DET
cblr-2960	49	9	effectiveness	effectiveness	NOUN
cblr-2960	49	10	of	of	ADP
cblr-2960	49	11	tax	tax	NOUN
cblr-2960	49	12	reform	reform	NOUN
cblr-2960	49	13	measures	measure	NOUN
cblr-2960	49	14	.	.	PUNCT
cblr-2960	50	1	finally	finally	ADV
cblr-2960	50	2	,	,	PUNCT
cblr-2960	50	3	part	part	NOUN
cblr-2960	50	4	v	v	INTJ
cblr-2960	50	5	applies	apply	VERB
cblr-2960	50	6	these	these	DET
cblr-2960	50	7	methods	method	NOUN
cblr-2960	50	8	to	to	PART
cblr-2960	50	9	examine	examine	VERB
cblr-2960	50	10	the	the	DET
cblr-2960	50	11	effectiveness	effectiveness	NOUN
cblr-2960	50	12	of	of	ADP
cblr-2960	50	13	the	the	DET
cblr-2960	50	14	tax	tax	NOUN
cblr-2960	50	15	agencies	agency	NOUN
cblr-2960	50	16	'	'	PART
cblr-2960	50	17	latest	late	ADJ
cblr-2960	50	18	targeted	target	VERB
cblr-2960	50	19	reforms	reform	NOUN
cblr-2960	50	20	,	,	PUNCT
cblr-2960	50	21	concluding	conclude	VERB
cblr-2960	50	22	that	that	SCONJ
cblr-2960	50	23	these	these	DET
cblr-2960	50	24	reforms	reform	NOUN
cblr-2960	50	25	were	be	AUX
cblr-2960	50	26	successful	successful	ADJ
cblr-2960	50	27	in	in	ADP
cblr-2960	50	28	deterring	deter	VERB
cblr-2960	50	29	the	the	DET
cblr-2960	50	30	use	use	NOUN
cblr-2960	50	31	of	of	ADP
cblr-2960	50	32	private	private	ADJ
cblr-2960	50	33	placement	placement	NOUN
cblr-2960	50	34	life	life	NOUN
cblr-2960	50	35	insurance	insurance	NOUN
cblr-2960	50	36	policies	policy	NOUN
cblr-2960	50	37	primarily	primarily	ADV
cblr-2960	50	38	as	as	ADP
cblr-2960	50	39	an	an	DET
cblr-2960	50	40	investment	investment	NOUN
cblr-2960	50	41	vehicle	vehicle	NOUN
cblr-2960	50	42	for	for	ADP
cblr-2960	50	43	hedge	hedge	NOUN
cblr-2960	50	44	funds	fund	NOUN
cblr-2960	50	45	.	.	PUNCT
cblr-2960	51	1	ii	ii	X
cblr-2960	51	2	.	.	PUNCT
cblr-2960	52	1	private	private	ADJ
cblr-2960	52	2	placement	placement	NOUN
cblr-2960	52	3	life	life	NOUN
cblr-2960	52	4	insurance	insurance	NOUN
cblr-2960	52	5	contracts	contract	NOUN
cblr-2960	52	6	life	life	NOUN
cblr-2960	52	7	insurance	insurance	NOUN
cblr-2960	52	8	enables	enable	VERB
cblr-2960	52	9	individuals	individual	NOUN
cblr-2960	52	10	to	to	PART
cblr-2960	52	11	make	make	VERB
cblr-2960	52	12	economic	economic	ADJ
cblr-2960	52	13	preparations	preparation	NOUN
cblr-2960	52	14	for	for	ADP
cblr-2960	52	15	retirement	retirement	NOUN
cblr-2960	52	16	and	and	CCONJ
cblr-2960	52	17	death	death	NOUN
cblr-2960	52	18	.	.	PUNCT
cblr-2960	53	1	12	12	NUM
cblr-2960	53	2	life	life	NOUN
cblr-2960	53	3	insurance	insurance	NOUN
cblr-2960	53	4	products	product	NOUN
cblr-2960	53	5	may	may	AUX
cblr-2960	53	6	be	be	AUX
cblr-2960	53	7	viewed	view	VERB
cblr-2960	53	8	along	along	ADP
cblr-2960	53	9	a	a	DET
cblr-2960	53	10	continuum	continuum	ADJ
cblr-2960	53	11	,	,	PUNCT
cblr-2960	53	12	ranging	range	VERB
cblr-2960	53	13	from	from	ADP
cblr-2960	53	14	pure	pure	ADJ
cblr-2960	53	15	insurance	insurance	NOUN
cblr-2960	53	16	products	product	NOUN
cblr-2960	53	17	to	to	ADP
cblr-2960	53	18	products	product	NOUN
cblr-2960	53	19	used	use	VERB
cblr-2960	53	20	solely	solely	ADV
cblr-2960	53	21	for	for	ADP
cblr-2960	53	22	investment	investment	NOUN
cblr-2960	53	23	purposes	purpose	NOUN
cblr-2960	53	24	.	.	PUNCT
cblr-2960	54	1	3	3	NUM
cblr-2960	54	2	term	term	NOUN
cblr-2960	54	3	life	life	NOUN
cblr-2960	54	4	insurance	insurance	NOUN
cblr-2960	54	5	is	be	AUX
cblr-2960	54	6	characterized	characterize	VERB
cblr-2960	54	7	as	as	ADP
cblr-2960	54	8	"	"	PUNCT
cblr-2960	54	9	pure	pure	ADJ
cblr-2960	54	10	"	"	PUNCT
cblr-2960	54	11	insurance	insurance	NOUN
cblr-2960	54	12	,	,	PUNCT
cblr-2960	54	13	where	where	SCONJ
cblr-2960	54	14	the	the	DET
cblr-2960	54	15	face	face	NOUN
cblr-2960	54	16	amount	amount	NOUN
cblr-2960	54	17	of	of	ADP
cblr-2960	54	18	the	the	DET
cblr-2960	54	19	policy	policy	NOUN
cblr-2960	54	20	is	be	AUX
cblr-2960	54	21	paid	pay	VERB
cblr-2960	54	22	to	to	ADP
cblr-2960	54	23	the	the	DET
cblr-2960	54	24	named	name	VERB
cblr-2960	54	25	beneficiary	beneficiary	NOUN
cblr-2960	54	26	upon	upon	SCONJ
cblr-2960	54	27	the	the	DET
cblr-2960	54	28	death	death	NOUN
cblr-2960	54	29	of	of	ADP
cblr-2960	54	30	the	the	DET
cblr-2960	54	31	insured	insure	VERB
cblr-2960	54	32	.	.	PUNCT
cblr-2960	55	1	4	4	NUM
cblr-2960	55	2	a	a	DET
cblr-2960	55	3	whole	whole	ADJ
cblr-2960	55	4	life	life	NOUN
cblr-2960	55	5	insurance	insurance	NOUN
cblr-2960	55	6	contract	contract	NOUN
cblr-2960	55	7	combines	combine	VERB
cblr-2960	55	8	a	a	DET
cblr-2960	55	9	term	term	NOUN
cblr-2960	55	10	policy	policy	NOUN
cblr-2960	55	11	with	with	ADP
cblr-2960	55	12	an	an	DET
cblr-2960	55	13	investment	investment	NOUN
cblr-2960	55	14	component	component	NOUN
cblr-2960	55	15	,	,	PUNCT
cblr-2960	55	16	where	where	SCONJ
cblr-2960	55	17	a	a	DET
cblr-2960	55	18	portion	portion	NOUN
cblr-2960	55	19	of	of	ADP
cblr-2960	55	20	the	the	DET
cblr-2960	55	21	policyholder	policyholder	NOUN
cblr-2960	55	22	's	's	PART
cblr-2960	55	23	premium	premium	NOUN
cblr-2960	55	24	is	be	AUX
cblr-2960	55	25	invested	invest	VERB
cblr-2960	55	26	in	in	ADP
cblr-2960	55	27	a	a	DET
cblr-2960	55	28	separate	separate	ADJ
cblr-2960	55	29	investment	investment	NOUN
cblr-2960	55	30	account	account	NOUN
cblr-2960	55	31	like	like	ADP
cblr-2960	55	32	a	a	DET
cblr-2960	55	33	hedge	hedge	NOUN
cblr-2960	55	34	fund	fund	NOUN
cblr-2960	55	35	.	.	PUNCT
cblr-2960	56	1	5	5	NUM
cblr-2960	56	2	a	a	DET
cblr-2960	56	3	private	private	ADJ
cblr-2960	56	4	placement	placement	NOUN
cblr-2960	56	5	life	life	NOUN
cblr-2960	56	6	insurance	insurance	NOUN
cblr-2960	56	7	contract	contract	NOUN
cblr-2960	56	8	is	be	AUX
cblr-2960	56	9	a	a	DET
cblr-2960	56	10	type	type	NOUN
cblr-2960	56	11	of	of	ADP
cblr-2960	56	12	variable	variable	ADJ
cblr-2960	56	13	universal	universal	ADJ
cblr-2960	56	14	life	life	NOUN
cblr-2960	56	15	12	12	NUM
cblr-2960	56	16	charlene	charlene	PROPN
cblr-2960	56	17	d.	d.	PROPN
cblr-2960	56	18	luke	luke	PROPN
cblr-2960	56	19	,	,	PUNCT
cblr-2960	56	20	taxing	tax	VERB
cblr-2960	56	21	risk	risk	NOUN
cblr-2960	56	22	:	:	PUNCT
cblr-2960	56	23	an	an	DET
cblr-2960	56	24	approach	approach	NOUN
cblr-2960	56	25	to	to	ADP
cblr-2960	56	26	variable	variable	ADJ
cblr-2960	56	27	insurance	insurance	NOUN
cblr-2960	56	28	reform	reform	NOUN
cblr-2960	56	29	,	,	PUNCT
cblr-2960	56	30	55	55	NUM
cblr-2960	56	31	buff	buff	NOUN
cblr-2960	56	32	.	.	PUNCT
cblr-2960	57	1	l.	l.	PROPN
cblr-2960	57	2	rev	rev	PROPN
cblr-2960	57	3	.	.	PROPN
cblr-2960	57	4	251	251	NUM
cblr-2960	57	5	,	,	PUNCT
cblr-2960	57	6	258	258	NUM
cblr-2960	57	7	(	(	PUNCT
cblr-2960	57	8	2007	2007	NUM
cblr-2960	57	9	)	)	PUNCT
cblr-2960	57	10	.	.	PUNCT
cblr-2960	58	1	13	13	NUM
cblr-2960	59	1	i	i	PRON
cblr-2960	59	2	d.	d.	PROPN
cblr-2960	59	3	14	14	NUM
cblr-2960	59	4	see	see	VERB
cblr-2960	59	5	smartmoney.com	smartmoney.com	X
cblr-2960	59	6	,	,	PUNCT
cblr-2960	59	7	term	term	NOUN
cblr-2960	59	8	or	or	CCONJ
cblr-2960	59	9	whole	whole	ADJ
cblr-2960	59	10	life	life	NOUN
cblr-2960	59	11	?	?	PUNCT
cblr-2960	59	12	,	,	PUNCT
cblr-2960	59	13	http://www.smart	http://www.smart	NOUN
cblr-2960	59	14	money.com/insurance/life/index.cfm?story=lifeterm	money.com/insurance/life/index.cfm?story=lifeterm	PROPN
cblr-2960	59	15	(	(	PUNCT
cblr-2960	59	16	last	last	ADV
cblr-2960	59	17	visited	visit	VERB
cblr-2960	59	18	feb	feb	PROPN
cblr-2960	59	19	.	.	PROPN
cblr-2960	59	20	11	11	NUM
cblr-2960	59	21	,	,	PUNCT
cblr-2960	59	22	2008	2008	NUM
cblr-2960	59	23	)	)	PUNCT
cblr-2960	59	24	(	(	PUNCT
cblr-2960	59	25	explaining	explain	VERB
cblr-2960	59	26	that	that	PRON
cblr-2960	59	27	term	term	NOUN
cblr-2960	59	28	insurance	insurance	NOUN
cblr-2960	59	29	can	can	AUX
cblr-2960	59	30	be	be	AUX
cblr-2960	59	31	purchased	purchase	VERB
cblr-2960	59	32	for	for	ADP
cblr-2960	59	33	periods	period	NOUN
cblr-2960	59	34	of	of	ADP
cblr-2960	59	35	one	one	NUM
cblr-2960	59	36	year	year	NOUN
cblr-2960	59	37	to	to	ADP
cblr-2960	59	38	thirty	thirty	NUM
cblr-2960	59	39	years	year	NOUN
cblr-2960	59	40	)	)	PUNCT
cblr-2960	59	41	.	.	PUNCT
cblr-2960	60	1	15	15	NUM
cblr-2960	60	2	kenneth	kenneth	PROPN
cblr-2960	60	3	black	black	PROPN
cblr-2960	60	4	,	,	PUNCT
cblr-2960	60	5	jr	jr	PROPN
cblr-2960	60	6	.	.	PROPN
cblr-2960	60	7	&	&	CCONJ
cblr-2960	60	8	harold	harold	PROPN
cblr-2960	60	9	skipper	skipper	PROPN
cblr-2960	60	10	,	,	PUNCT
cblr-2960	60	11	jr	jr	PROPN
cblr-2960	60	12	.	.	PROPN
cblr-2960	60	13	,	,	PUNCT
cblr-2960	60	14	life	life	NOUN
cblr-2960	60	15	&	&	CCONJ
cblr-2960	60	16	health	health	PROPN
cblr-2960	60	17	insurance	insurance	PROPN
cblr-2960	60	18	127	127	NUM
cblr-2960	60	19	(	(	PUNCT
cblr-2960	60	20	13th	13th	NOUN
cblr-2960	60	21	ed	ed	NOUN
cblr-2960	60	22	.	.	PROPN
cblr-2960	60	23	2000	2000	NUM
cblr-2960	60	24	)	)	PUNCT
cblr-2960	60	25	.	.	PUNCT
cblr-2960	61	1	no	no	INTJ
cblr-2960	61	2	.	.	PUNCT
cblr-2960	62	1	2:694	2:694	NUM
cblr-2960	62	2	]	]	X
cblr-2960	62	3	columbia	columbia	PROPN
cblr-2960	62	4	business	business	PROPN
cblr-2960	62	5	law	law	PROPN
cblr-2960	62	6	review	review	NOUN
cblr-2960	62	7	insurance	insurance	NOUN
cblr-2960	62	8	contract	contract	NOUN
cblr-2960	62	9	6	6	NUM
cblr-2960	62	10	that	that	PRON
cblr-2960	62	11	is	be	AUX
cblr-2960	62	12	tied	tie	VERB
cblr-2960	62	13	to	to	ADP
cblr-2960	62	14	the	the	DET
cblr-2960	62	15	investment	investment	NOUN
cblr-2960	62	16	performance	performance	NOUN
cblr-2960	62	17	of	of	ADP
cblr-2960	62	18	accounts	account	NOUN
cblr-2960	62	19	that	that	PRON
cblr-2960	62	20	are	be	AUX
cblr-2960	62	21	segregated	segregate	VERB
cblr-2960	62	22	from	from	ADP
cblr-2960	62	23	the	the	DET
cblr-2960	62	24	general	general	ADJ
cblr-2960	62	25	accounts	account	NOUN
cblr-2960	62	26	of	of	ADP
cblr-2960	62	27	the	the	DET
cblr-2960	62	28	issuing	issue	VERB
cblr-2960	62	29	company	company	NOUN
cblr-2960	62	30	.	.	PUNCT
cblr-2960	63	1	7	7	NUM
cblr-2960	63	2	policyholders	policyholder	NOUN
cblr-2960	63	3	can	can	AUX
cblr-2960	63	4	invest	invest	VERB
cblr-2960	63	5	in	in	ADP
cblr-2960	63	6	a	a	DET
cblr-2960	63	7	wide	wide	ADJ
cblr-2960	63	8	range	range	NOUN
cblr-2960	63	9	of	of	ADP
cblr-2960	63	10	underlying	underlie	VERB
cblr-2960	63	11	products	product	NOUN
cblr-2960	63	12	,	,	PUNCT
cblr-2960	63	13	including	include	VERB
cblr-2960	63	14	hedge	hedge	NOUN
cblr-2960	63	15	funds	fund	NOUN
cblr-2960	63	16	.	.	PUNCT
cblr-2960	63	17	'8	'8	PUNCT
cblr-2960	64	1	compared	compare	VERB
cblr-2960	64	2	to	to	ADP
cblr-2960	64	3	traditional	traditional	ADJ
cblr-2960	64	4	retail	retail	ADJ
cblr-2960	64	5	contracts	contract	NOUN
cblr-2960	64	6	,	,	PUNCT
cblr-2960	64	7	private	private	ADJ
cblr-2960	64	8	placement	placement	NOUN
cblr-2960	64	9	life	life	NOUN
cblr-2960	64	10	insurance	insurance	NOUN
cblr-2960	64	11	has	have	AUX
cblr-2960	64	12	substantially	substantially	ADV
cblr-2960	64	13	reduced	reduce	VERB
cblr-2960	64	14	costs	cost	NOUN
cblr-2960	64	15	and	and	CCONJ
cblr-2960	64	16	increased	increase	VERB
cblr-2960	64	17	investment	investment	NOUN
cblr-2960	64	18	choices	choice	NOUN
cblr-2960	64	19	.	.	PUNCT
cblr-2960	65	1	9	9	NUM
cblr-2960	65	2	these	these	DET
cblr-2960	65	3	contracts	contract	NOUN
cblr-2960	65	4	also	also	ADV
cblr-2960	65	5	typically	typically	ADV
cblr-2960	65	6	have	have	VERB
cblr-2960	65	7	minimum	minimum	ADJ
cblr-2960	65	8	annual	annual	ADJ
cblr-2960	65	9	premiums	premium	NOUN
cblr-2960	65	10	of	of	ADP
cblr-2960	65	11	at	at	ADV
cblr-2960	65	12	least	least	ADV
cblr-2960	65	13	$	$	SYM
cblr-2960	65	14	1	1	NUM
cblr-2960	65	15	million	million	NUM
cblr-2960	65	16	and	and	CCONJ
cblr-2960	65	17	are	be	AUX
cblr-2960	65	18	most	most	ADV
cblr-2960	65	19	often	often	ADV
cblr-2960	65	20	a	a	DET
cblr-2960	65	21	planning	planning	NOUN
cblr-2960	65	22	tool	tool	NOUN
cblr-2960	65	23	for	for	ADP
cblr-2960	65	24	wealthier	wealthy	ADJ
cblr-2960	65	25	individuals	individual	NOUN
cblr-2960	65	26	.	.	PUNCT
cblr-2960	65	27	"	"	PUNCT
cblr-2960	66	1	an	an	DET
cblr-2960	66	2	investor	investor	NOUN
cblr-2960	66	3	must	must	AUX
cblr-2960	66	4	meet	meet	VERB
cblr-2960	66	5	the	the	DET
cblr-2960	66	6	definition	definition	NOUN
cblr-2960	66	7	of	of	ADP
cblr-2960	66	8	a	a	DET
cblr-2960	66	9	"	"	PUNCT
cblr-2960	66	10	qualified	qualified	ADJ
cblr-2960	66	11	purchaser"21	purchaser"21	NOUN
cblr-2960	66	12	and	and	CCONJ
cblr-2960	66	13	an	an	DET
cblr-2960	66	14	"	"	PUNCT
cblr-2960	66	15	accredited	accredited	ADJ
cblr-2960	66	16	investor"22	investor"22	PROPN
cblr-2960	66	17	in	in	ADP
cblr-2960	66	18	order	order	NOUN
cblr-2960	66	19	to	to	PART
cblr-2960	66	20	purchase	purchase	VERB
cblr-2960	66	21	a	a	DET
cblr-2960	66	22	private	private	ADJ
cblr-2960	66	23	placement	placement	NOUN
cblr-2960	66	24	life	life	NOUN
cblr-2960	66	25	insurance	insurance	NOUN
cblr-2960	66	26	product	product	NOUN
cblr-2960	66	27	.	.	PUNCT
cblr-2960	67	1	16	16	NUM
cblr-2960	67	2	variable	variable	ADJ
cblr-2960	67	3	life	life	NOUN
cblr-2960	67	4	insurance	insurance	NOUN
cblr-2960	67	5	policies	policy	NOUN
cblr-2960	67	6	allow	allow	VERB
cblr-2960	67	7	policyholders	policyholder	NOUN
cblr-2960	67	8	to	to	PART
cblr-2960	67	9	invest	invest	VERB
cblr-2960	67	10	a	a	DET
cblr-2960	67	11	portion	portion	NOUN
cblr-2960	67	12	of	of	ADP
cblr-2960	67	13	their	their	PRON
cblr-2960	67	14	premiums	premium	NOUN
cblr-2960	67	15	in	in	ADP
cblr-2960	67	16	separate	separate	ADJ
cblr-2960	67	17	investment	investment	NOUN
cblr-2960	67	18	accounts	account	NOUN
cblr-2960	67	19	,	,	PUNCT
cblr-2960	67	20	allowing	allow	VERB
cblr-2960	67	21	the	the	DET
cblr-2960	67	22	policyholder	policyholder	NOUN
cblr-2960	67	23	to	to	PART
cblr-2960	67	24	obtain	obtain	VERB
cblr-2960	67	25	risk	risk	NOUN
cblr-2960	67	26	based	base	VERB
cblr-2960	67	27	returns	return	NOUN
cblr-2960	67	28	.	.	PUNCT
cblr-2960	68	1	i	i	PRON
cblr-2960	68	2	d.	d.	VERB
cblr-2960	68	3	the	the	DET
cblr-2960	68	4	amount	amount	NOUN
cblr-2960	68	5	of	of	ADP
cblr-2960	68	6	the	the	DET
cblr-2960	68	7	cash	cash	NOUN
cblr-2960	68	8	value	value	NOUN
cblr-2960	68	9	and	and	CCONJ
cblr-2960	68	10	death	death	NOUN
cblr-2960	68	11	benefit	benefit	NOUN
cblr-2960	68	12	varies	vary	VERB
cblr-2960	68	13	with	with	ADP
cblr-2960	68	14	the	the	DET
cblr-2960	68	15	performance	performance	NOUN
cblr-2960	68	16	of	of	ADP
cblr-2960	68	17	the	the	DET
cblr-2960	68	18	underlying	underlie	VERB
cblr-2960	68	19	assets	asset	NOUN
cblr-2960	68	20	.	.	PUNCT
cblr-2960	69	1	i	i	PRON
cblr-2960	69	2	d.	d.	PROPN
cblr-2960	69	3	universal	universal	PROPN
cblr-2960	69	4	life	life	NOUN
cblr-2960	69	5	insurance	insurance	NOUN
cblr-2960	69	6	policies	policy	NOUN
cblr-2960	69	7	give	give	VERB
cblr-2960	69	8	the	the	DET
cblr-2960	69	9	policyholder	policyholder	NOUN
cblr-2960	69	10	the	the	DET
cblr-2960	69	11	flexibility	flexibility	NOUN
cblr-2960	69	12	to	to	PART
cblr-2960	69	13	adjust	adjust	VERB
cblr-2960	69	14	the	the	DET
cblr-2960	69	15	amount	amount	NOUN
cblr-2960	69	16	of	of	ADP
cblr-2960	69	17	premium	premium	NOUN
cblr-2960	69	18	payments	payment	NOUN
cblr-2960	69	19	.	.	PUNCT
cblr-2960	70	1	i	i	PRON
cblr-2960	70	2	d.	d.	PROPN
cblr-2960	70	3	at	at	ADP
cblr-2960	70	4	114	114	NUM
cblr-2960	70	5	.	.	PUNCT
cblr-2960	71	1	17	17	NUM
cblr-2960	71	2	see	see	VERB
cblr-2960	71	3	markuson	markuson	PROPN
cblr-2960	71	4	,	,	PUNCT
cblr-2960	71	5	supra	supra	PROPN
cblr-2960	71	6	note	note	PROPN
cblr-2960	71	7	4	4	NUM
cblr-2960	71	8	,	,	PUNCT
cblr-2960	71	9	at	at	ADP
cblr-2960	71	10	3	3	NUM
cblr-2960	71	11	.	.	NOUN
cblr-2960	71	12	8	8	NUM
cblr-2960	71	13	see	see	VERB
cblr-2960	71	14	silverman	silverman	NOUN
cblr-2960	71	15	,	,	PUNCT
cblr-2960	71	16	supra	supra	PROPN
cblr-2960	71	17	note	note	PROPN
cblr-2960	71	18	6	6	NUM
cblr-2960	71	19	(	(	PUNCT
cblr-2960	71	20	noting	note	VERB
cblr-2960	71	21	that	that	SCONJ
cblr-2960	71	22	private	private	ADJ
cblr-2960	71	23	placement	placement	NOUN
cblr-2960	71	24	products	product	NOUN
cblr-2960	71	25	allow	allow	VERB
cblr-2960	71	26	investors	investor	NOUN
cblr-2960	71	27	to	to	PART
cblr-2960	71	28	utilize	utilize	VERB
cblr-2960	71	29	a	a	DET
cblr-2960	71	30	range	range	NOUN
cblr-2960	71	31	of	of	ADP
cblr-2960	71	32	options	option	NOUN
cblr-2960	71	33	,	,	PUNCT
cblr-2960	71	34	including	include	VERB
cblr-2960	71	35	hedge	hedge	NOUN
cblr-2960	71	36	funds	fund	NOUN
cblr-2960	71	37	,	,	PUNCT
cblr-2960	71	38	derivatives	derivative	NOUN
cblr-2960	71	39	,	,	PUNCT
cblr-2960	71	40	and	and	CCONJ
cblr-2960	71	41	real	real	ADJ
cblr-2960	71	42	estate	estate	NOUN
cblr-2960	71	43	investment	investment	NOUN
cblr-2960	71	44	trusts	trust	NOUN
cblr-2960	71	45	)	)	PUNCT
cblr-2960	71	46	.	.	PUNCT
cblr-2960	72	1	19	19	NUM
cblr-2960	72	2	see	see	VERB
cblr-2960	72	3	markuson	markuson	PROPN
cblr-2960	72	4	,	,	PUNCT
cblr-2960	72	5	supra	supra	PROPN
cblr-2960	72	6	note	note	PROPN
cblr-2960	72	7	4	4	NUM
cblr-2960	72	8	,	,	PUNCT
cblr-2960	72	9	at	at	ADP
cblr-2960	72	10	1	1	NUM
cblr-2960	72	11	(	(	PUNCT
cblr-2960	72	12	"	"	PUNCT
cblr-2960	72	13	[	[	X
cblr-2960	72	14	private	private	ADJ
cblr-2960	72	15	placement	placement	NOUN
cblr-2960	72	16	life	life	NOUN
cblr-2960	72	17	insurance	insurance	NOUN
cblr-2960	72	18	]	]	PUNCT
cblr-2960	72	19	is	be	AUX
cblr-2960	72	20	a	a	DET
cblr-2960	72	21	variable	variable	ADJ
cblr-2960	72	22	universal	universal	ADJ
cblr-2960	72	23	life	life	NOUN
cblr-2960	72	24	contract	contract	NOUN
cblr-2960	72	25	that	that	PRON
cblr-2960	72	26	has	have	AUX
cblr-2960	72	27	stripped	strip	VERB
cblr-2960	72	28	out	out	ADP
cblr-2960	72	29	all	all	PRON
cblr-2960	72	30	of	of	ADP
cblr-2960	72	31	the	the	DET
cblr-2960	72	32	retail	retail	ADJ
cblr-2960	72	33	pricing	pricing	NOUN
cblr-2960	72	34	and	and	CCONJ
cblr-2960	72	35	markups	markup	NOUN
cblr-2960	72	36	,	,	PUNCT
cblr-2960	72	37	while	while	SCONJ
cblr-2960	72	38	at	at	ADP
cblr-2960	72	39	the	the	DET
cblr-2960	72	40	same	same	ADJ
cblr-2960	72	41	time	time	NOUN
cblr-2960	72	42	allowing	allow	VERB
cblr-2960	72	43	policy	policy	NOUN
cblr-2960	72	44	owners	owner	NOUN
cblr-2960	72	45	to	to	PART
cblr-2960	72	46	choose	choose	VERB
cblr-2960	72	47	and/or	and/or	CCONJ
cblr-2960	72	48	suggest	suggest	VERB
cblr-2960	72	49	the	the	DET
cblr-2960	72	50	use	use	NOUN
cblr-2960	72	51	of	of	ADP
cblr-2960	72	52	specific	specific	ADJ
cblr-2960	72	53	investment	investment	NOUN
cblr-2960	72	54	managers	manager	NOUN
cblr-2960	72	55	,	,	PUNCT
cblr-2960	72	56	subject	subject	ADJ
cblr-2960	72	57	to	to	ADP
cblr-2960	72	58	normal	normal	ADJ
cblr-2960	72	59	due	due	ADJ
cblr-2960	72	60	diligence	diligence	NOUN
cblr-2960	72	61	and	and	CCONJ
cblr-2960	72	62	investor	investor	NOUN
cblr-2960	72	63	control	control	NOUN
cblr-2960	72	64	issues	issue	NOUN
cblr-2960	72	65	.	.	PUNCT
cblr-2960	72	66	"	"	PUNCT
cblr-2960	72	67	)	)	PUNCT
cblr-2960	72	68	.	.	PUNCT
cblr-2960	73	1	20	20	NUM
cblr-2960	74	1	i	i	PRON
cblr-2960	74	2	d.	d.	PROPN
cblr-2960	74	3	(	(	PUNCT
cblr-2960	74	4	noting	note	VERB
cblr-2960	74	5	that	that	SCONJ
cblr-2960	74	6	only	only	ADV
cblr-2960	74	7	very	very	ADV
cblr-2960	74	8	affluent	affluent	ADJ
cblr-2960	74	9	investors	investor	NOUN
cblr-2960	74	10	will	will	AUX
cblr-2960	74	11	be	be	AUX
cblr-2960	74	12	able	able	ADJ
cblr-2960	74	13	to	to	PART
cblr-2960	74	14	afford	afford	VERB
cblr-2960	74	15	the	the	DET
cblr-2960	74	16	high	high	ADJ
cblr-2960	74	17	premiums	premium	NOUN
cblr-2960	74	18	of	of	ADP
cblr-2960	74	19	private	private	ADJ
cblr-2960	74	20	placement	placement	NOUN
cblr-2960	74	21	products	product	NOUN
cblr-2960	74	22	)	)	PUNCT
cblr-2960	74	23	;	;	PUNCT
cblr-2960	74	24	see	see	VERB
cblr-2960	74	25	also	also	ADV
cblr-2960	74	26	david	david	PROPN
cblr-2960	74	27	m.	m.	PROPN
cblr-2960	74	28	schizer	schizer	PROPN
cblr-2960	74	29	,	,	PUNCT
cblr-2960	74	30	frictions	friction	NOUN
cblr-2960	74	31	as	as	ADP
cblr-2960	74	32	a	a	DET
cblr-2960	74	33	constraint	constraint	NOUN
cblr-2960	74	34	on	on	ADP
cblr-2960	74	35	tax	tax	NOUN
cblr-2960	74	36	planning	planning	NOUN
cblr-2960	74	37	,	,	PUNCT
cblr-2960	74	38	101	101	NUM
cblr-2960	74	39	colum	colum	NOUN
cblr-2960	74	40	.	.	PUNCT
cblr-2960	75	1	l.	l.	PROPN
cblr-2960	75	2	rev	rev	PROPN
cblr-2960	75	3	.	.	PROPN
cblr-2960	75	4	1312	1312	NUM
cblr-2960	75	5	,	,	PUNCT
cblr-2960	75	6	1384	1384	NUM
cblr-2960	75	7	(	(	PUNCT
cblr-2960	75	8	2001	2001	NUM
cblr-2960	75	9	)	)	PUNCT
cblr-2960	75	10	(	(	PUNCT
cblr-2960	75	11	"	"	PUNCT
cblr-2960	75	12	while	while	SCONJ
cblr-2960	75	13	variable	variable	ADJ
cblr-2960	75	14	contracts	contract	NOUN
cblr-2960	75	15	based	base	VERB
cblr-2960	75	16	on	on	ADP
cblr-2960	75	17	bonds	bond	NOUN
cblr-2960	75	18	and	and	CCONJ
cblr-2960	75	19	mutual	mutual	ADJ
cblr-2960	75	20	funds	fund	NOUN
cblr-2960	75	21	are	be	AUX
cblr-2960	75	22	a	a	DET
cblr-2960	75	23	staple	staple	NOUN
cblr-2960	75	24	of	of	ADP
cblr-2960	75	25	middle	middle	ADJ
cblr-2960	75	26	class	class	NOUN
cblr-2960	75	27	tax	tax	NOUN
cblr-2960	75	28	planning	planning	NOUN
cblr-2960	75	29	,	,	PUNCT
cblr-2960	75	30	contracts	contract	NOUN
cblr-2960	75	31	based	base	VERB
cblr-2960	75	32	on	on	ADP
cblr-2960	75	33	hedge	hedge	NOUN
cblr-2960	75	34	fund	fund	NOUN
cblr-2960	75	35	returns	return	NOUN
cblr-2960	75	36	are	be	AUX
cblr-2960	75	37	available	available	ADJ
cblr-2960	75	38	only	only	ADV
cblr-2960	75	39	in	in	ADP
cblr-2960	75	40	private	private	ADJ
cblr-2960	75	41	transactions	transaction	NOUN
cblr-2960	75	42	for	for	ADP
cblr-2960	75	43	very	very	ADV
cblr-2960	75	44	wealthy	wealthy	ADJ
cblr-2960	75	45	taxpayers	taxpayer	NOUN
cblr-2960	75	46	.	.	PUNCT
cblr-2960	76	1	"	"	PUNCT
cblr-2960	76	2	)	)	PUNCT
cblr-2960	76	3	.	.	PUNCT
cblr-2960	77	1	21	21	NUM
cblr-2960	77	2	a	a	DET
cblr-2960	77	3	qualified	qualified	ADJ
cblr-2960	77	4	purchaser	purchaser	NOUN
cblr-2960	77	5	is	be	AUX
cblr-2960	77	6	a	a	DET
cblr-2960	77	7	natural	natural	ADJ
cblr-2960	77	8	person	person	NOUN
cblr-2960	77	9	with	with	ADP
cblr-2960	77	10	at	at	ADV
cblr-2960	77	11	least	least	ADV
cblr-2960	77	12	$	$	SYM
cblr-2960	77	13	5	5	NUM
cblr-2960	77	14	million	million	NUM
cblr-2960	77	15	in	in	ADP
cblr-2960	77	16	investable	investable	ADJ
cblr-2960	77	17	assets	asset	NOUN
cblr-2960	77	18	or	or	CCONJ
cblr-2960	77	19	a	a	DET
cblr-2960	77	20	corporation	corporation	NOUN
cblr-2960	77	21	or	or	CCONJ
cblr-2960	77	22	trust	trust	NOUN
cblr-2960	77	23	with	with	ADP
cblr-2960	77	24	at	at	ADV
cblr-2960	77	25	least	least	ADV
cblr-2960	77	26	$	$	SYM
cblr-2960	77	27	25	25	NUM
cblr-2960	77	28	million	million	NUM
cblr-2960	77	29	in	in	ADP
cblr-2960	77	30	investments	investment	NOUN
cblr-2960	77	31	,	,	PUNCT
cblr-2960	77	32	excluding	exclude	VERB
cblr-2960	77	33	pension	pension	NOUN
cblr-2960	77	34	and	and	CCONJ
cblr-2960	77	35	employee	employee	NOUN
cblr-2960	77	36	benefit	benefit	NOUN
cblr-2960	77	37	plans	plan	NOUN
cblr-2960	77	38	.	.	PUNCT
cblr-2960	78	1	17	17	NUM
cblr-2960	78	2	c.f.r	c.f.r	NOUN
cblr-2960	78	3	.	.	PUNCT
cblr-2960	79	1	§	§	PROPN
cblr-2960	79	2	270.2(a)(51	270.2(a)(51	NUM
cblr-2960	79	3	)	)	PUNCT
cblr-2960	79	4	(	(	PUNCT
cblr-2960	79	5	2008	2008	NUM
cblr-2960	79	6	)	)	PUNCT
cblr-2960	79	7	.	.	PUNCT
cblr-2960	80	1	22	22	NUM
cblr-2960	80	2	an	an	DET
cblr-2960	80	3	accredited	accredited	ADJ
cblr-2960	80	4	investor	investor	NOUN
cblr-2960	80	5	is	be	AUX
cblr-2960	80	6	any	any	DET
cblr-2960	80	7	natural	natural	ADJ
cblr-2960	80	8	person	person	NOUN
cblr-2960	80	9	whose	whose	DET
cblr-2960	80	10	individual	individual	ADJ
cblr-2960	80	11	net	net	ADJ
cblr-2960	80	12	worth	worth	NOUN
cblr-2960	80	13	,	,	PUNCT
cblr-2960	80	14	or	or	CCONJ
cblr-2960	80	15	joint	joint	ADJ
cblr-2960	80	16	net	net	ADJ
cblr-2960	80	17	worth	worth	NOUN
cblr-2960	80	18	with	with	ADP
cblr-2960	80	19	that	that	DET
cblr-2960	80	20	person	person	NOUN
cblr-2960	80	21	's	's	PART
cblr-2960	80	22	spouse	spouse	NOUN
cblr-2960	80	23	,	,	PUNCT
cblr-2960	80	24	at	at	ADP
cblr-2960	80	25	the	the	DET
cblr-2960	80	26	time	time	NOUN
cblr-2960	80	27	of	of	ADP
cblr-2960	80	28	his	his	PRON
cblr-2960	80	29	purchase	purchase	NOUN
cblr-2960	80	30	exceeds	exceed	VERB
cblr-2960	80	31	$	$	SYM
cblr-2960	80	32	1,000,000	1,000,000	NUM
cblr-2960	80	33	or	or	CCONJ
cblr-2960	80	34	any	any	DET
cblr-2960	80	35	natural	natural	ADJ
cblr-2960	80	36	person	person	NOUN
cblr-2960	80	37	who	who	PRON
cblr-2960	80	38	had	have	VERB
cblr-2960	80	39	an	an	DET
cblr-2960	80	40	individual	individual	ADJ
cblr-2960	80	41	income	income	NOUN
cblr-2960	80	42	in	in	ADP
cblr-2960	80	43	excess	excess	NOUN
cblr-2960	80	44	of	of	ADP
cblr-2960	80	45	$	$	SYM
cblr-2960	80	46	200,000	200,000	NUM
cblr-2960	80	47	in	in	ADP
cblr-2960	80	48	each	each	PRON
cblr-2960	80	49	of	of	ADP
cblr-2960	80	50	the	the	DET
cblr-2960	80	51	two	two	NUM
cblr-2960	80	52	most	most	ADV
cblr-2960	80	53	recent	recent	ADJ
cblr-2960	80	54	years	year	NOUN
cblr-2960	80	55	or	or	CCONJ
cblr-2960	80	56	joint	joint	ADJ
cblr-2960	80	57	income	income	NOUN
cblr-2960	80	58	with	with	ADP
cblr-2960	80	59	that	that	DET
cblr-2960	80	60	person	person	NOUN
cblr-2960	80	61	's	's	PART
cblr-2960	80	62	spouse	spouse	NOUN
cblr-2960	80	63	in	in	ADP
cblr-2960	80	64	excess	excess	NOUN
cblr-2960	80	65	of	of	ADP
cblr-2960	80	66	$	$	SYM
cblr-2960	80	67	300,000	300,000	NUM
cblr-2960	80	68	in	in	ADP
cblr-2960	80	69	each	each	PRON
cblr-2960	80	70	of	of	ADP
cblr-2960	80	71	those	those	PRON
cblr-2960	80	72	[	[	X
cblr-2960	80	73	vol	vol	NOUN
cblr-2960	80	74	.	.	NOUN
cblr-2960	80	75	2008	2008	NUM
cblr-2960	80	76	job	job	NOUN
cblr-2960	80	77	well	well	ADV
cblr-2960	80	78	done	do	VERB
cblr-2960	80	79	private	private	ADJ
cblr-2960	80	80	placement	placement	NOUN
cblr-2960	80	81	life	life	NOUN
cblr-2960	80	82	insurance	insurance	NOUN
cblr-2960	80	83	initially	initially	ADV
cblr-2960	80	84	developed	develop	VERB
cblr-2960	80	85	as	as	ADP
cblr-2960	80	86	a	a	DET
cblr-2960	80	87	way	way	NOUN
cblr-2960	80	88	to	to	PART
cblr-2960	80	89	provide	provide	VERB
cblr-2960	80	90	low	low	ADJ
cblr-2960	80	91	-	-	PUNCT
cblr-2960	80	92	cost	cost	NOUN
cblr-2960	80	93	insurance	insurance	NOUN
cblr-2960	80	94	to	to	ADP
cblr-2960	80	95	companies	company	NOUN
cblr-2960	80	96	that	that	PRON
cblr-2960	80	97	needed	need	VERB
cblr-2960	80	98	to	to	PART
cblr-2960	80	99	fund	fund	VERB
cblr-2960	80	100	benefit	benefit	NOUN
cblr-2960	80	101	programs	program	NOUN
cblr-2960	80	102	for	for	ADP
cblr-2960	80	103	senior	senior	ADJ
cblr-2960	80	104	executives.23	executives.23	PROPN
cblr-2960	80	105	it	it	PRON
cblr-2960	80	106	was	be	AUX
cblr-2960	80	107	not	not	PART
cblr-2960	80	108	until	until	SCONJ
cblr-2960	80	109	such	such	ADJ
cblr-2960	80	110	policies	policy	NOUN
cblr-2960	80	111	were	be	AUX
cblr-2960	80	112	pitched	pitch	VERB
cblr-2960	80	113	to	to	ADP
cblr-2960	80	114	wealthy	wealthy	ADJ
cblr-2960	80	115	individuals	individual	NOUN
cblr-2960	80	116	in	in	ADP
cblr-2960	80	117	the	the	DET
cblr-2960	80	118	midto	midto	ADJ
cblr-2960	80	119	late-1990s	late-1990	NOUN
cblr-2960	80	120	that	that	PRON
cblr-2960	80	121	people	people	NOUN
cblr-2960	80	122	began	begin	VERB
cblr-2960	80	123	recognizing	recognize	VERB
cblr-2960	80	124	the	the	DET
cblr-2960	80	125	potential	potential	ADJ
cblr-2960	80	126	tax	tax	NOUN
cblr-2960	80	127	benefits	benefit	NOUN
cblr-2960	80	128	for	for	ADP
cblr-2960	80	129	hedge	hedge	NOUN
cblr-2960	80	130	fund	fund	NOUN
cblr-2960	80	131	investors.24	investors.24	PROPN
cblr-2960	80	132	as	as	ADP
cblr-2960	80	133	a	a	DET
cblr-2960	80	134	general	general	ADJ
cblr-2960	80	135	rule	rule	NOUN
cblr-2960	80	136	,	,	PUNCT
cblr-2960	80	137	the	the	DET
cblr-2960	80	138	investment	investment	NOUN
cblr-2960	80	139	return	return	NOUN
cblr-2960	80	140	5	5	NUM
cblr-2960	80	141	accrued	accrue	VERB
cblr-2960	80	142	within	within	ADP
cblr-2960	80	143	life	life	NOUN
cblr-2960	80	144	insurance	insurance	NOUN
cblr-2960	80	145	policies	policy	NOUN
cblr-2960	80	146	is	be	AUX
cblr-2960	80	147	free	free	ADJ
cblr-2960	80	148	from	from	ADP
cblr-2960	80	149	current	current	ADJ
cblr-2960	80	150	inclusion	inclusion	NOUN
cblr-2960	80	151	in	in	ADP
cblr-2960	80	152	gross	gross	ADJ
cblr-2960	80	153	income	income	NOUN
cblr-2960	80	154	to	to	ADP
cblr-2960	80	155	the	the	DET
cblr-2960	80	156	policyholder.2	policyholder.2	PROPN
cblr-2960	80	157	private	private	ADJ
cblr-2960	80	158	placement	placement	NOUN
cblr-2960	80	159	life	life	NOUN
cblr-2960	80	160	insurance	insurance	NOUN
cblr-2960	80	161	contracts	contract	NOUN
cblr-2960	80	162	therefore	therefore	ADV
cblr-2960	80	163	offer	offer	VERB
cblr-2960	80	164	investors	investor	NOUN
cblr-2960	80	165	an	an	DET
cblr-2960	80	166	opportunity	opportunity	NOUN
cblr-2960	80	167	for	for	ADP
cblr-2960	80	168	substantial	substantial	ADJ
cblr-2960	80	169	tax	tax	NOUN
cblr-2960	80	170	-	-	PUNCT
cblr-2960	80	171	free	free	ADJ
cblr-2960	80	172	buildup	buildup	NOUN
cblr-2960	80	173	of	of	ADP
cblr-2960	80	174	investment	investment	NOUN
cblr-2960	80	175	benefits	benefit	NOUN
cblr-2960	80	176	,	,	PUNCT
cblr-2960	80	177	while	while	SCONJ
cblr-2960	80	178	still	still	ADV
cblr-2960	80	179	allowing	allow	VERB
cblr-2960	80	180	for	for	ADP
cblr-2960	80	181	life	life	NOUN
cblr-2960	80	182	insurance	insurance	NOUN
cblr-2960	80	183	distributions	distribution	NOUN
cblr-2960	80	184	and	and	CCONJ
cblr-2960	80	185	loans	loan	NOUN
cblr-2960	80	186	.	.	PUNCT
cblr-2960	81	1	in	in	ADP
cblr-2960	81	2	essence	essence	NOUN
cblr-2960	81	3	,	,	PUNCT
cblr-2960	81	4	a	a	DET
cblr-2960	81	5	private	private	ADJ
cblr-2960	81	6	placement	placement	NOUN
cblr-2960	81	7	wrapper	wrapper	NOUN
cblr-2960	81	8	combines	combine	VERB
cblr-2960	81	9	sought	seek	VERB
cblr-2960	81	10	-	-	PUNCT
cblr-2960	81	11	after	after	ADP
cblr-2960	81	12	investment	investment	NOUN
cblr-2960	81	13	results	result	NOUN
cblr-2960	81	14	with	with	ADP
cblr-2960	81	15	the	the	DET
cblr-2960	81	16	tax	tax	NOUN
cblr-2960	81	17	advantages	advantage	NOUN
cblr-2960	81	18	of	of	ADP
cblr-2960	81	19	a	a	DET
cblr-2960	81	20	life	life	NOUN
cblr-2960	81	21	insurance	insurance	NOUN
cblr-2960	81	22	policy.28	policy.28	ADV
cblr-2960	81	23	following	follow	VERB
cblr-2960	81	24	the	the	DET
cblr-2960	81	25	discovery	discovery	NOUN
cblr-2960	81	26	of	of	ADP
cblr-2960	81	27	private	private	ADJ
cblr-2960	81	28	years	year	NOUN
cblr-2960	81	29	and	and	CCONJ
cblr-2960	81	30	has	have	VERB
cblr-2960	81	31	a	a	DET
cblr-2960	81	32	reasonable	reasonable	ADJ
cblr-2960	81	33	expectation	expectation	NOUN
cblr-2960	81	34	of	of	ADP
cblr-2960	81	35	reaching	reach	VERB
cblr-2960	81	36	the	the	DET
cblr-2960	81	37	same	same	ADJ
cblr-2960	81	38	income	income	NOUN
cblr-2960	81	39	level	level	NOUN
cblr-2960	81	40	in	in	ADP
cblr-2960	81	41	the	the	DET
cblr-2960	81	42	current	current	ADJ
cblr-2960	81	43	year	year	NOUN
cblr-2960	81	44	.	.	PUNCT
cblr-2960	82	1	17	17	NUM
cblr-2960	82	2	c.f.r	c.f.r	NOUN
cblr-2960	82	3	.	.	PUNCT
cblr-2960	83	1	§	§	PROPN
cblr-2960	83	2	230.501	230.501	NUM
cblr-2960	83	3	(	(	PUNCT
cblr-2960	83	4	2008	2008	NUM
cblr-2960	83	5	)	)	PUNCT
cblr-2960	83	6	.	.	PUNCT
cblr-2960	84	1	23	23	NUM
cblr-2960	84	2	see	see	VERB
cblr-2960	84	3	markuson	markuson	PROPN
cblr-2960	84	4	,	,	PUNCT
cblr-2960	84	5	supra	supra	PROPN
cblr-2960	84	6	note	note	PROPN
cblr-2960	84	7	4	4	NUM
cblr-2960	84	8	,	,	PUNCT
cblr-2960	84	9	at	at	ADP
cblr-2960	84	10	2	2	NUM
cblr-2960	84	11	(	(	PUNCT
cblr-2960	84	12	noting	note	VERB
cblr-2960	84	13	that	that	SCONJ
cblr-2960	84	14	senior	senior	ADJ
cblr-2960	84	15	executives	executive	NOUN
cblr-2960	84	16	often	often	ADV
cblr-2960	84	17	desired	desire	VERB
cblr-2960	84	18	"	"	PUNCT
cblr-2960	84	19	greater	great	ADJ
cblr-2960	84	20	investment	investment	NOUN
cblr-2960	84	21	options	option	NOUN
cblr-2960	84	22	,	,	PUNCT
cblr-2960	84	23	lower	low	ADJ
cblr-2960	84	24	fees	fee	NOUN
cblr-2960	84	25	,	,	PUNCT
cblr-2960	84	26	and	and	CCONJ
cblr-2960	84	27	greater	great	ADJ
cblr-2960	84	28	overall	overall	ADJ
cblr-2960	84	29	customization	customization	NOUN
cblr-2960	84	30	"	"	PUNCT
cblr-2960	84	31	)	)	PUNCT
cblr-2960	84	32	;	;	PUNCT
cblr-2960	84	33	see	see	VERB
cblr-2960	84	34	also	also	ADV
cblr-2960	84	35	colter	colter	PROPN
cblr-2960	84	36	,	,	PUNCT
cblr-2960	84	37	supra	supra	PROPN
cblr-2960	84	38	note	note	PROPN
cblr-2960	84	39	7	7	NUM
cblr-2960	84	40	(	(	PUNCT
cblr-2960	84	41	explaining	explain	VERB
cblr-2960	84	42	that	that	SCONJ
cblr-2960	84	43	private	private	ADJ
cblr-2960	84	44	placement	placement	NOUN
cblr-2960	84	45	life	life	NOUN
cblr-2960	84	46	insurance	insurance	NOUN
cblr-2960	84	47	developed	develop	VERB
cblr-2960	84	48	from	from	ADP
cblr-2960	84	49	the	the	DET
cblr-2960	84	50	need	need	NOUN
cblr-2960	84	51	to	to	PART
cblr-2960	84	52	fund	fund	VERB
cblr-2960	84	53	executive	executive	ADJ
cblr-2960	84	54	-	-	PUNCT
cblr-2960	84	55	benefit	benefit	NOUN
cblr-2960	84	56	programs	program	NOUN
cblr-2960	84	57	)	)	PUNCT
cblr-2960	84	58	.	.	PUNCT
cblr-2960	85	1	24	24	NUM
cblr-2960	85	2	see	see	VERB
cblr-2960	85	3	colter	colter	PROPN
cblr-2960	85	4	,	,	PUNCT
cblr-2960	85	5	supra	supra	PROPN
cblr-2960	85	6	note	note	NOUN
cblr-2960	85	7	7	7	NUM
cblr-2960	85	8	.	.	SYM
cblr-2960	85	9	25	25	NUM
cblr-2960	85	10	luke	luke	ADJ
cblr-2960	85	11	,	,	PUNCT
cblr-2960	85	12	supra	supra	PROPN
cblr-2960	85	13	note	note	NOUN
cblr-2960	85	14	3	3	NUM
cblr-2960	85	15	,	,	PUNCT
cblr-2960	85	16	at	at	ADP
cblr-2960	85	17	130	130	NUM
cblr-2960	85	18	(	(	PUNCT
cblr-2960	85	19	explaining	explain	VERB
cblr-2960	85	20	that	that	SCONJ
cblr-2960	85	21	the	the	DET
cblr-2960	85	22	investment	investment	NOUN
cblr-2960	85	23	return	return	NOUN
cblr-2960	85	24	earned	earn	VERB
cblr-2960	85	25	on	on	ADP
cblr-2960	85	26	the	the	DET
cblr-2960	85	27	premiums	premium	NOUN
cblr-2960	85	28	paid	pay	VERB
cblr-2960	85	29	for	for	ADP
cblr-2960	85	30	qualifying	qualify	VERB
cblr-2960	85	31	cash	cash	NOUN
cblr-2960	85	32	value	value	NOUN
cblr-2960	85	33	life	life	NOUN
cblr-2960	85	34	insurance	insurance	NOUN
cblr-2960	85	35	is	be	AUX
cblr-2960	85	36	often	often	ADV
cblr-2960	85	37	referred	refer	VERB
cblr-2960	85	38	to	to	ADP
cblr-2960	85	39	as	as	ADP
cblr-2960	85	40	"	"	PUNCT
cblr-2960	85	41	inside	inside	ADJ
cblr-2960	85	42	buildup	buildup	NOUN
cblr-2960	85	43	"	"	PUNCT
cblr-2960	85	44	)	)	PUNCT
cblr-2960	85	45	.	.	PUNCT
cblr-2960	86	1	26	26	NUM
cblr-2960	86	2	see	see	VERB
cblr-2960	86	3	i.r.c	i.r.c	NOUN
cblr-2960	86	4	.	.	PUNCT
cblr-2960	87	1	§	§	PROPN
cblr-2960	87	2	7702(g	7702(g	NUM
cblr-2960	87	3	)	)	PUNCT
cblr-2960	88	1	(	(	PUNCT
cblr-2960	88	2	providing	provide	VERB
cblr-2960	88	3	that	that	SCONJ
cblr-2960	88	4	"	"	PUNCT
cblr-2960	88	5	[	[	X
cblr-2960	88	6	i]f	i]f	NOUN
cblr-2960	88	7	at	at	ADP
cblr-2960	88	8	any	any	DET
cblr-2960	88	9	time	time	NOUN
cblr-2960	88	10	any	any	DET
cblr-2960	88	11	contract	contract	NOUN
cblr-2960	88	12	which	which	PRON
cblr-2960	88	13	is	be	AUX
cblr-2960	88	14	a	a	DET
cblr-2960	88	15	life	life	NOUN
cblr-2960	88	16	insurance	insurance	NOUN
cblr-2960	88	17	contract	contract	NOUN
cblr-2960	88	18	under	under	ADP
cblr-2960	88	19	the	the	DET
cblr-2960	88	20	applicable	applicable	ADJ
cblr-2960	88	21	law	law	NOUN
cblr-2960	88	22	does	do	AUX
cblr-2960	88	23	not	not	PART
cblr-2960	88	24	meet	meet	VERB
cblr-2960	88	25	the	the	DET
cblr-2960	88	26	definition	definition	NOUN
cblr-2960	88	27	of	of	ADP
cblr-2960	88	28	life	life	NOUN
cblr-2960	88	29	insurance	insurance	NOUN
cblr-2960	88	30	contract	contract	NOUN
cblr-2960	88	31	under	under	ADP
cblr-2960	88	32	subsection	subsection	NOUN
cblr-2960	88	33	(	(	PUNCT
cblr-2960	88	34	a	a	NOUN
cblr-2960	88	35	)	)	PUNCT
cblr-2960	88	36	,	,	PUNCT
cblr-2960	88	37	the	the	DET
cblr-2960	88	38	income	income	NOUN
cblr-2960	88	39	on	on	ADP
cblr-2960	88	40	the	the	DET
cblr-2960	88	41	contract	contract	NOUN
cblr-2960	88	42	for	for	ADP
cblr-2960	88	43	any	any	DET
cblr-2960	88	44	taxable	taxable	ADJ
cblr-2960	88	45	year	year	NOUN
cblr-2960	88	46	of	of	ADP
cblr-2960	88	47	the	the	DET
cblr-2960	88	48	policyholder	policyholder	NOUN
cblr-2960	88	49	shall	shall	AUX
cblr-2960	88	50	be	be	AUX
cblr-2960	88	51	treated	treat	VERB
cblr-2960	88	52	as	as	ADP
cblr-2960	88	53	ordinary	ordinary	ADJ
cblr-2960	88	54	income	income	NOUN
cblr-2960	88	55	received	receive	VERB
cblr-2960	88	56	or	or	CCONJ
cblr-2960	88	57	accrued	accrue	VERB
cblr-2960	88	58	by	by	ADP
cblr-2960	88	59	the	the	DET
cblr-2960	88	60	policyholder	policyholder	NOUN
cblr-2960	88	61	during	during	ADP
cblr-2960	88	62	such	such	ADJ
cblr-2960	88	63	year	year	NOUN
cblr-2960	88	64	.	.	PUNCT
cblr-2960	88	65	"	"	PUNCT
cblr-2960	88	66	)	)	PUNCT
cblr-2960	88	67	.	.	PUNCT
cblr-2960	89	1	27	27	NUM
cblr-2960	89	2	michael	michael	PROPN
cblr-2960	89	3	j.	j.	PROPN
cblr-2960	89	4	goldberg	goldberg	PROPN
cblr-2960	89	5	,	,	PUNCT
cblr-2960	89	6	tax	tax	NOUN
cblr-2960	89	7	clinic	clinic	NOUN
cblr-2960	89	8	practical	practical	ADJ
cblr-2960	89	9	advice	advice	NOUN
cblr-2960	89	10	on	on	ADP
cblr-2960	89	11	current	current	ADJ
cblr-2960	89	12	issues	issue	NOUN
cblr-2960	89	13	:	:	PUNCT
cblr-2960	89	14	gains	gain	NOUN
cblr-2960	89	15	&	&	CCONJ
cblr-2960	89	16	losses	loss	NOUN
cblr-2960	89	17	how	how	SCONJ
cblr-2960	89	18	to	to	PART
cblr-2960	89	19	use	use	VERB
cblr-2960	89	20	a	a	DET
cblr-2960	89	21	life	life	NOUN
cblr-2960	89	22	insurance	insurance	NOUN
cblr-2960	89	23	wrapper	wrapper	NOUN
cblr-2960	89	24	to	to	PART
cblr-2960	89	25	minimize	minimize	VERB
cblr-2960	89	26	taxes	taxis	NOUN
cblr-2960	89	27	on	on	ADP
cblr-2960	89	28	securities	security	NOUN
cblr-2960	89	29	investments	investment	NOUN
cblr-2960	89	30	,	,	PUNCT
cblr-2960	89	31	the	the	DET
cblr-2960	89	32	tax	tax	NOUN
cblr-2960	89	33	adviser	adviser	NOUN
cblr-2960	89	34	,	,	PUNCT
cblr-2960	89	35	2	2	NUM
cblr-2960	89	36	-	-	SYM
cblr-2960	89	37	01	01	NUM
cblr-2960	89	38	t.t.a	t.t.a	NOUN
cblr-2960	89	39	.	.	PROPN
cblr-2960	89	40	90	90	NUM
cblr-2960	89	41	(	(	PUNCT
cblr-2960	89	42	2001	2001	NUM
cblr-2960	89	43	)	)	PUNCT
cblr-2960	89	44	;	;	PUNCT
cblr-2960	89	45	see	see	VERB
cblr-2960	89	46	i.r.c	i.r.c	NOUN
cblr-2960	89	47	.	.	PUNCT
cblr-2960	90	1	§	§	PROPN
cblr-2960	90	2	72(e)(5	72(e)(5	NUM
cblr-2960	90	3	)	)	PUNCT
cblr-2960	90	4	(	(	PUNCT
cblr-2960	90	5	providing	provide	VERB
cblr-2960	90	6	that	that	SCONJ
cblr-2960	90	7	distributions	distribution	NOUN
cblr-2960	90	8	from	from	ADP
cblr-2960	90	9	life	life	NOUN
cblr-2960	90	10	insurance	insurance	NOUN
cblr-2960	90	11	shall	shall	AUX
cblr-2960	90	12	be	be	AUX
cblr-2960	90	13	included	include	VERB
cblr-2960	90	14	in	in	ADP
cblr-2960	90	15	gross	gross	ADJ
cblr-2960	90	16	income	income	NOUN
cblr-2960	90	17	,	,	PUNCT
cblr-2960	90	18	but	but	CCONJ
cblr-2960	90	19	only	only	ADV
cblr-2960	90	20	to	to	ADP
cblr-2960	90	21	the	the	DET
cblr-2960	90	22	extent	extent	NOUN
cblr-2960	90	23	they	they	PRON
cblr-2960	90	24	exceed	exceed	VERB
cblr-2960	90	25	the	the	DET
cblr-2960	90	26	investment	investment	NOUN
cblr-2960	90	27	in	in	ADP
cblr-2960	90	28	the	the	DET
cblr-2960	90	29	contract	contract	NOUN
cblr-2960	90	30	)	)	PUNCT
cblr-2960	90	31	;	;	PUNCT
cblr-2960	90	32	see	see	VERB
cblr-2960	90	33	generally	generally	ADV
cblr-2960	90	34	i.r.c	i.r.c	NOUN
cblr-2960	90	35	.	.	PUNCT
cblr-2960	91	1	§	§	PROPN
cblr-2960	91	2	72(e	72(e	NUM
cblr-2960	91	3	)	)	PUNCT
cblr-2960	91	4	(	(	PUNCT
cblr-2960	91	5	stating	state	VERB
cblr-2960	91	6	that	that	SCONJ
cblr-2960	91	7	loans	loan	NOUN
cblr-2960	91	8	tied	tie	VERB
cblr-2960	91	9	to	to	ADP
cblr-2960	91	10	the	the	DET
cblr-2960	91	11	cash	cash	NOUN
cblr-2960	91	12	surrender	surrender	NOUN
cblr-2960	91	13	value	value	NOUN
cblr-2960	91	14	are	be	AUX
cblr-2960	91	15	not	not	PART
cblr-2960	91	16	treated	treat	VERB
cblr-2960	91	17	as	as	ADP
cblr-2960	91	18	distributions	distribution	NOUN
cblr-2960	91	19	)	)	PUNCT
cblr-2960	91	20	.	.	PUNCT
cblr-2960	92	1	28	28	NUM
cblr-2960	92	2	see	see	VERB
cblr-2960	92	3	goldberg	goldberg	PROPN
cblr-2960	92	4	,	,	PUNCT
cblr-2960	92	5	supra	supra	PROPN
cblr-2960	92	6	note	note	PROPN
cblr-2960	92	7	27	27	NUM
cblr-2960	92	8	(	(	PUNCT
cblr-2960	92	9	explaining	explain	VERB
cblr-2960	92	10	that	that	SCONJ
cblr-2960	92	11	a	a	DET
cblr-2960	92	12	private	private	ADJ
cblr-2960	92	13	placement	placement	NOUN
cblr-2960	92	14	life	life	NOUN
cblr-2960	92	15	insurance	insurance	NOUN
cblr-2960	92	16	wrapper	wrapper	NOUN
cblr-2960	92	17	offers	offer	VERB
cblr-2960	92	18	substantial	substantial	ADJ
cblr-2960	92	19	tax	tax	NOUN
cblr-2960	92	20	-	-	PUNCT
cblr-2960	92	21	free	free	ADJ
cblr-2960	92	22	buildup	buildup	NOUN
cblr-2960	92	23	of	of	ADP
cblr-2960	92	24	gains	gain	NOUN
cblr-2960	92	25	of	of	ADP
cblr-2960	92	26	investments	investment	NOUN
cblr-2960	92	27	)	)	PUNCT
cblr-2960	92	28	.	.	PUNCT
cblr-2960	93	1	no	no	INTJ
cblr-2960	93	2	.	.	PUNCT
cblr-2960	94	1	2:694	2:694	NUM
cblr-2960	94	2	]	]	X
cblr-2960	94	3	columbia	columbia	PROPN
cblr-2960	94	4	business	business	PROPN
cblr-2960	94	5	la	la	PROPN
cblr-2960	94	6	w	w	PROPN
cblr-2960	94	7	review	review	PROPN
cblr-2960	94	8	placement	placement	NOUN
cblr-2960	94	9	life	life	NOUN
cblr-2960	94	10	insurance	insurance	NOUN
cblr-2960	94	11	tax	tax	NOUN
cblr-2960	94	12	benefits	benefit	NOUN
cblr-2960	94	13	and	and	CCONJ
cblr-2960	94	14	fueled	fuel	VERB
cblr-2960	94	15	by	by	ADP
cblr-2960	94	16	the	the	DET
cblr-2960	94	17	hedge	hedge	PROPN
cblr-2960	94	18	fund	fund	NOUN
cblr-2960	94	19	industry	industry	NOUN
cblr-2960	94	20	's	's	PART
cblr-2960	94	21	growth	growth	NOUN
cblr-2960	94	22	,	,	PUNCT
cblr-2960	94	23	many	many	ADJ
cblr-2960	94	24	life	life	NOUN
cblr-2960	94	25	insurance	insurance	NOUN
cblr-2960	94	26	products	product	NOUN
cblr-2960	94	27	were	be	AUX
cblr-2960	94	28	developed	develop	VERB
cblr-2960	94	29	specifically	specifically	ADV
cblr-2960	94	30	for	for	ADP
cblr-2960	94	31	hedge	hedge	NOUN
cblr-2960	94	32	fund	fund	NOUN
cblr-2960	94	33	investments.29	investments.29	PROPN
cblr-2960	94	34	life	life	NOUN
cblr-2960	94	35	insurance	insurance	NOUN
cblr-2960	94	36	contracts	contract	NOUN
cblr-2960	94	37	that	that	PRON
cblr-2960	94	38	are	be	AUX
cblr-2960	94	39	primarily	primarily	ADV
cblr-2960	94	40	investment	investment	NOUN
cblr-2960	94	41	motivated	motivated	ADJ
cblr-2960	94	42	cut	cut	VERB
cblr-2960	94	43	against	against	ADP
cblr-2960	94	44	legitimate	legitimate	ADJ
cblr-2960	94	45	mortality	mortality	NOUN
cblr-2960	94	46	planning	planning	NOUN
cblr-2960	94	47	and	and	CCONJ
cblr-2960	94	48	are	be	AUX
cblr-2960	94	49	mechanisms	mechanism	NOUN
cblr-2960	94	50	for	for	ADP
cblr-2960	94	51	tax	tax	NOUN
cblr-2960	94	52	avoidance	avoidance	NOUN
cblr-2960	94	53	.	.	PUNCT
cblr-2960	94	54	"	"	PUNCT
cblr-2960	95	1	life	life	NOUN
cblr-2960	95	2	insurance	insurance	NOUN
cblr-2960	95	3	products	product	NOUN
cblr-2960	95	4	provide	provide	VERB
cblr-2960	95	5	for	for	ADP
cblr-2960	95	6	two	two	NUM
cblr-2960	95	7	significant	significant	ADJ
cblr-2960	95	8	tax	tax	NOUN
cblr-2960	95	9	benefits	benefit	NOUN
cblr-2960	95	10	:	:	PUNCT
cblr-2960	95	11	deferral	deferral	ADJ
cblr-2960	95	12	of	of	ADP
cblr-2960	95	13	tax	tax	NOUN
cblr-2960	95	14	on	on	ADP
cblr-2960	95	15	buildup	buildup	NOUN
cblr-2960	95	16	on	on	ADP
cblr-2960	95	17	investments	investment	NOUN
cblr-2960	95	18	inside	inside	ADP
cblr-2960	95	19	the	the	DET
cblr-2960	95	20	policy	policy	NOUN
cblr-2960	95	21	and	and	CCONJ
cblr-2960	95	22	exclusion	exclusion	NOUN
cblr-2960	95	23	from	from	ADP
cblr-2960	95	24	gross	gross	ADJ
cblr-2960	95	25	income	income	NOUN
cblr-2960	95	26	of	of	ADP
cblr-2960	95	27	proceeds	proceed	NOUN
cblr-2960	95	28	received	receive	VERB
cblr-2960	95	29	under	under	ADP
cblr-2960	95	30	the	the	DET
cblr-2960	95	31	life	life	NOUN
cblr-2960	95	32	insurance	insurance	NOUN
cblr-2960	95	33	upon	upon	SCONJ
cblr-2960	95	34	death	death	NOUN
cblr-2960	95	35	of	of	ADP
cblr-2960	95	36	the	the	DET
cblr-2960	95	37	insured	insure	VERB
cblr-2960	95	38	.	.	PUNCT
cblr-2960	95	39	"	"	PUNCT
cblr-2960	96	1	life	life	NOUN
cblr-2960	96	2	insurance	insurance	NOUN
cblr-2960	96	3	policies	policy	NOUN
cblr-2960	96	4	that	that	PRON
cblr-2960	96	5	are	be	AUX
cblr-2960	96	6	purchased	purchase	VERB
cblr-2960	96	7	purely	purely	ADV
cblr-2960	96	8	for	for	SCONJ
cblr-2960	96	9	investment	investment	NOUN
cblr-2960	96	10	to	to	PART
cblr-2960	96	11	reap	reap	VERB
cblr-2960	96	12	the	the	DET
cblr-2960	96	13	tax	tax	NOUN
cblr-2960	96	14	benefits	benefit	NOUN
cblr-2960	96	15	may	may	AUX
cblr-2960	96	16	be	be	AUX
cblr-2960	96	17	considered	consider	VERB
cblr-2960	96	18	a	a	DET
cblr-2960	96	19	tax	tax	NOUN
cblr-2960	96	20	shelter	shelter	NOUN
cblr-2960	96	21	.	.	PUNCT
cblr-2960	97	1	while	while	SCONJ
cblr-2960	97	2	not	not	PART
cblr-2960	97	3	all	all	DET
cblr-2960	97	4	tax	tax	NOUN
cblr-2960	97	5	shelters	shelter	NOUN
cblr-2960	97	6	are	be	AUX
cblr-2960	97	7	illegal,32	illegal,32	VERB
cblr-2960	97	8	the	the	DET
cblr-2960	97	9	aim	aim	NOUN
cblr-2960	97	10	of	of	ADP
cblr-2960	97	11	every	every	DET
cblr-2960	97	12	tax	tax	NOUN
cblr-2960	97	13	shelter	shelter	NOUN
cblr-2960	97	14	is	be	AUX
cblr-2960	97	15	to	to	PART
cblr-2960	97	16	create	create	VERB
cblr-2960	97	17	a	a	DET
cblr-2960	97	18	tax	tax	NOUN
cblr-2960	97	19	benefit	benefit	NOUN
cblr-2960	97	20	in	in	ADP
cblr-2960	97	21	the	the	DET
cblr-2960	97	22	form	form	NOUN
cblr-2960	97	23	of	of	ADP
cblr-2960	97	24	a	a	DET
cblr-2960	97	25	loss	loss	NOUN
cblr-2960	97	26	,	,	PUNCT
cblr-2960	97	27	expense	expense	NOUN
cblr-2960	97	28	,	,	PUNCT
cblr-2960	97	29	or	or	CCONJ
cblr-2960	97	30	exclusion	exclusion	NOUN
cblr-2960	97	31	from	from	ADP
cblr-2960	97	32	gross	gross	ADJ
cblr-2960	97	33	income	income	NOUN
cblr-2960	97	34	that	that	PRON
cblr-2960	97	35	has	have	VERB
cblr-2960	97	36	no	no	DET
cblr-2960	97	37	economic	economic	ADJ
cblr-2960	97	38	significance	significance	NOUN
cblr-2960	97	39	and	and	CCONJ
cblr-2960	97	40	is	be	AUX
cblr-2960	97	41	simply	simply	ADV
cblr-2960	97	42	the	the	DET
cblr-2960	97	43	consequence	consequence	NOUN
cblr-2960	97	44	of	of	ADP
cblr-2960	97	45	rule	rule	NOUN
cblr-2960	97	46	manipulation.3	manipulation.3	PROPN
cblr-2960	97	47	therefore	therefore	ADV
cblr-2960	97	48	,	,	PUNCT
cblr-2960	97	49	life	life	NOUN
cblr-2960	97	50	insurance	insurance	NOUN
cblr-2960	97	51	policies	policy	NOUN
cblr-2960	97	52	that	that	PRON
cblr-2960	97	53	are	be	AUX
cblr-2960	97	54	in	in	ADP
cblr-2960	97	55	serious	serious	ADJ
cblr-2960	97	56	contemplation	contemplation	NOUN
cblr-2960	97	57	of	of	ADP
cblr-2960	97	58	death	death	NOUN
cblr-2960	97	59	are	be	AUX
cblr-2960	97	60	legitimate	legitimate	ADJ
cblr-2960	97	61	planning	planning	NOUN
cblr-2960	97	62	devices	device	NOUN
cblr-2960	97	63	,	,	PUNCT
cblr-2960	97	64	while	while	SCONJ
cblr-2960	97	65	insurance	insurance	NOUN
cblr-2960	97	66	policies	policy	NOUN
cblr-2960	97	67	purchased	purchase	VERB
cblr-2960	97	68	strictly	strictly	ADV
cblr-2960	97	69	for	for	ADP
cblr-2960	97	70	investment	investment	NOUN
cblr-2960	97	71	and	and	CCONJ
cblr-2960	97	72	tax	tax	NOUN
cblr-2960	97	73	benefits	benefit	NOUN
cblr-2960	97	74	are	be	AUX
cblr-2960	97	75	tax	tax	NOUN
cblr-2960	97	76	shelters	shelter	NOUN
cblr-2960	97	77	that	that	PRON
cblr-2960	97	78	compel	compel	VERB
cblr-2960	97	79	government	government	NOUN
cblr-2960	97	80	action	action	NOUN
cblr-2960	97	81	.	.	PUNCT
cblr-2960	98	1	a	a	DET
cblr-2960	98	2	short	short	ADJ
cblr-2960	98	3	example	example	NOUN
cblr-2960	98	4	will	will	AUX
cblr-2960	98	5	illustrate	illustrate	VERB
cblr-2960	98	6	how	how	SCONJ
cblr-2960	98	7	much	much	ADJ
cblr-2960	98	8	is	be	AUX
cblr-2960	98	9	at	at	ADP
cblr-2960	98	10	stake	stake	NOUN
cblr-2960	98	11	if	if	SCONJ
cblr-2960	98	12	a	a	DET
cblr-2960	98	13	taxpayer	taxpayer	NOUN
cblr-2960	98	14	successfully	successfully	ADV
cblr-2960	98	15	uses	use	VERB
cblr-2960	98	16	private	private	ADJ
cblr-2960	98	17	placement	placement	NOUN
cblr-2960	98	18	life	life	NOUN
cblr-2960	98	19	insurance	insurance	NOUN
cblr-2960	98	20	29	29	NUM
cblr-2960	98	21	grant	grant	PROPN
cblr-2960	98	22	r.	r.	PROPN
cblr-2960	98	23	markuson	markuson	PROPN
cblr-2960	98	24	,	,	PUNCT
cblr-2960	98	25	private	private	ADJ
cblr-2960	98	26	placement	placement	NOUN
cblr-2960	98	27	life	life	NOUN
cblr-2960	98	28	insurance	insurance	NOUN
cblr-2960	98	29	:	:	PUNCT
cblr-2960	98	30	new	new	ADJ
cblr-2960	98	31	insights	insight	NOUN
cblr-2960	98	32	for	for	ADP
cblr-2960	98	33	an	an	DET
cblr-2960	98	34	enduring	endure	VERB
cblr-2960	98	35	technique	technique	NOUN
cblr-2960	98	36	,	,	PUNCT
cblr-2960	98	37	trusts	trust	NOUN
cblr-2960	98	38	&	&	CCONJ
cblr-2960	98	39	estates	estate	NOUN
cblr-2960	98	40	,	,	PUNCT
cblr-2960	98	41	advertising	advertising	NOUN
cblr-2960	98	42	supplement	supplement	NOUN
cblr-2960	98	43	,	,	PUNCT
cblr-2960	98	44	dec	dec	PROPN
cblr-2960	98	45	.	.	PROPN
cblr-2960	98	46	2002	2002	NUM
cblr-2960	98	47	,	,	PUNCT
cblr-2960	98	48	at	at	ADP
cblr-2960	98	49	2	2	NUM
cblr-2960	98	50	(	(	PUNCT
cblr-2960	98	51	describing	describe	VERB
cblr-2960	98	52	that	that	SCONJ
cblr-2960	98	53	the	the	DET
cblr-2960	98	54	growth	growth	NOUN
cblr-2960	98	55	of	of	ADP
cblr-2960	98	56	the	the	DET
cblr-2960	98	57	hedge	hedge	NOUN
cblr-2960	98	58	fund	fund	NOUN
cblr-2960	98	59	industry	industry	NOUN
cblr-2960	98	60	in	in	ADP
cblr-2960	98	61	the	the	DET
cblr-2960	98	62	1990s	1990	NOUN
cblr-2960	98	63	led	lead	VERB
cblr-2960	98	64	to	to	ADP
cblr-2960	98	65	products	product	NOUN
cblr-2960	98	66	being	be	AUX
cblr-2960	98	67	tailored	tailor	VERB
cblr-2960	98	68	specifically	specifically	ADV
cblr-2960	98	69	for	for	ADP
cblr-2960	98	70	hedge	hedge	NOUN
cblr-2960	98	71	fund	fund	NOUN
cblr-2960	98	72	investments	investment	NOUN
cblr-2960	98	73	)	)	PUNCT
cblr-2960	98	74	,	,	PUNCT
cblr-2960	98	75	available	available	ADJ
cblr-2960	98	76	at	at	ADP
cblr-2960	98	77	http://www.m-nlaw.com/t&egrant.pdf	http://www.m-nlaw.com/t&egrant.pdf	PROPN
cblr-2960	98	78	.	.	PUNCT
cblr-2960	99	1	30	30	NUM
cblr-2960	99	2	see	see	VERB
cblr-2960	99	3	luke	luke	PROPN
cblr-2960	99	4	,	,	PUNCT
cblr-2960	99	5	supra	supra	PROPN
cblr-2960	99	6	note	note	NOUN
cblr-2960	99	7	12	12	NUM
cblr-2960	99	8	,	,	PUNCT
cblr-2960	99	9	at	at	ADP
cblr-2960	99	10	257	257	NUM
cblr-2960	99	11	(	(	PUNCT
cblr-2960	99	12	explaining	explain	VERB
cblr-2960	99	13	that	that	SCONJ
cblr-2960	99	14	congress	congress	PROPN
cblr-2960	99	15	has	have	AUX
cblr-2960	99	16	acted	act	VERB
cblr-2960	99	17	to	to	PART
cblr-2960	99	18	prevent	prevent	VERB
cblr-2960	99	19	insurance	insurance	NOUN
cblr-2960	99	20	products	product	NOUN
cblr-2960	99	21	from	from	ADP
cblr-2960	99	22	becoming	become	VERB
cblr-2960	99	23	overly	overly	ADV
cblr-2960	99	24	investment	investment	NOUN
cblr-2960	99	25	oriented	orient	VERB
cblr-2960	99	26	or	or	CCONJ
cblr-2960	99	27	overly	overly	ADV
cblr-2960	99	28	prone	prone	ADJ
cblr-2960	99	29	to	to	PART
cblr-2960	99	30	use	use	VERB
cblr-2960	99	31	in	in	ADP
cblr-2960	99	32	tax	tax	NOUN
cblr-2960	99	33	shelters	shelter	NOUN
cblr-2960	99	34	)	)	PUNCT
cblr-2960	99	35	.	.	PUNCT
cblr-2960	100	1	"	"	PUNCT
cblr-2960	100	2	'	'	PUNCT
cblr-2960	100	3	see	see	VERB
cblr-2960	100	4	i.r.c	i.r.c	NOUN
cblr-2960	100	5	.	.	PUNCT
cblr-2960	101	1	§	§	PROPN
cblr-2960	101	2	61(a	61(a	NUM
cblr-2960	101	3	)	)	PUNCT
cblr-2960	101	4	(	(	PUNCT
cblr-2960	101	5	stating	state	VERB
cblr-2960	101	6	that	that	SCONJ
cblr-2960	101	7	gains	gain	NOUN
cblr-2960	101	8	on	on	ADP
cblr-2960	101	9	investments	investment	NOUN
cblr-2960	101	10	within	within	ADP
cblr-2960	101	11	life	life	NOUN
cblr-2960	101	12	insurance	insurance	NOUN
cblr-2960	101	13	policies	policy	NOUN
cblr-2960	101	14	are	be	AUX
cblr-2960	101	15	not	not	PART
cblr-2960	101	16	realized	realize	VERB
cblr-2960	101	17	income	income	NOUN
cblr-2960	101	18	)	)	PUNCT
cblr-2960	101	19	;	;	PUNCT
cblr-2960	101	20	see	see	VERB
cblr-2960	101	21	also	also	ADV
cblr-2960	101	22	i.r.c	i.r.c	NOUN
cblr-2960	101	23	.	.	PUNCT
cblr-2960	102	1	§	§	PROPN
cblr-2960	102	2	7702(g	7702(g	NUM
cblr-2960	102	3	)	)	PUNCT
cblr-2960	102	4	;	;	PUNCT
cblr-2960	102	5	i.r.c	i.r.c	NOUN
cblr-2960	102	6	.	.	PUNCT
cblr-2960	103	1	§	§	PROPN
cblr-2960	103	2	101(a	101(a	PROPN
cblr-2960	103	3	)	)	PUNCT
cblr-2960	103	4	(	(	PUNCT
cblr-2960	103	5	"	"	PUNCT
cblr-2960	103	6	[	[	X
cblr-2960	103	7	glross	glross	ADJ
cblr-2960	103	8	income	income	NOUN
cblr-2960	103	9	does	do	AUX
cblr-2960	103	10	not	not	PART
cblr-2960	103	11	include	include	VERB
cblr-2960	103	12	amounts	amount	NOUN
cblr-2960	103	13	received	receive	VERB
cblr-2960	103	14	..	..	PUNCT
cblr-2960	103	15	.	.	PUNCT
cblr-2960	104	1	under	under	ADP
cblr-2960	104	2	a	a	DET
cblr-2960	104	3	life	life	NOUN
cblr-2960	104	4	insurance	insurance	NOUN
cblr-2960	104	5	contract	contract	NOUN
cblr-2960	104	6	,	,	PUNCT
cblr-2960	104	7	if	if	SCONJ
cblr-2960	104	8	such	such	ADJ
cblr-2960	104	9	amounts	amount	NOUN
cblr-2960	104	10	are	be	AUX
cblr-2960	104	11	paid	pay	VERB
cblr-2960	104	12	by	by	ADP
cblr-2960	104	13	reason	reason	NOUN
cblr-2960	104	14	of	of	ADP
cblr-2960	104	15	the	the	DET
cblr-2960	104	16	death	death	NOUN
cblr-2960	104	17	of	of	ADP
cblr-2960	104	18	the	the	DET
cblr-2960	104	19	insured	insure	VERB
cblr-2960	104	20	.	.	PUNCT
cblr-2960	104	21	"	"	PUNCT
cblr-2960	104	22	)	)	PUNCT
cblr-2960	104	23	.	.	PUNCT
cblr-2960	105	1	"	"	PUNCT
cblr-2960	105	2	see	see	VERB
cblr-2960	105	3	editorial	editorial	NOUN
cblr-2960	105	4	,	,	PUNCT
cblr-2960	105	5	the	the	DET
cblr-2960	105	6	irs	irs	PROPN
cblr-2960	105	7	out	out	ADP
cblr-2960	105	8	of	of	ADP
cblr-2960	105	9	control	control	NOUN
cblr-2960	105	10	,	,	PUNCT
cblr-2960	105	11	wall	wall	PROPN
cblr-2960	105	12	st	st	PROPN
cblr-2960	105	13	.	.	PROPN
cblr-2960	105	14	j.	j.	PROPN
cblr-2960	105	15	,	,	PUNCT
cblr-2960	105	16	july	july	PROPN
cblr-2960	105	17	17	17	NUM
cblr-2960	105	18	,	,	PUNCT
cblr-2960	105	19	2002	2002	NUM
cblr-2960	105	20	,	,	PUNCT
cblr-2960	105	21	at	at	ADP
cblr-2960	105	22	a16	a16	PROPN
cblr-2960	105	23	(	(	PUNCT
cblr-2960	105	24	arguing	argue	VERB
cblr-2960	105	25	that	that	SCONJ
cblr-2960	105	26	it	it	PRON
cblr-2960	105	27	is	be	AUX
cblr-2960	105	28	not	not	PART
cblr-2960	105	29	against	against	ADP
cblr-2960	105	30	the	the	DET
cblr-2960	105	31	law	law	NOUN
cblr-2960	105	32	to	to	PART
cblr-2960	105	33	minimize	minimize	VERB
cblr-2960	105	34	one	one	NUM
cblr-2960	105	35	's	's	PART
cblr-2960	105	36	tax	tax	NOUN
cblr-2960	105	37	burden	burden	NOUN
cblr-2960	105	38	and	and	CCONJ
cblr-2960	105	39	it	it	PRON
cblr-2960	105	40	is	be	AUX
cblr-2960	105	41	common	common	ADJ
cblr-2960	105	42	sense	sense	NOUN
cblr-2960	105	43	to	to	PART
cblr-2960	105	44	do	do	VERB
cblr-2960	105	45	so	so	ADV
cblr-2960	105	46	)	)	PUNCT
cblr-2960	105	47	.	.	PUNCT
cblr-2960	105	48	"	"	PUNCT
cblr-2960	106	1	see	see	VERB
cblr-2960	106	2	marvin	marvin	PROPN
cblr-2960	106	3	a.	a.	PROPN
cblr-2960	106	4	chirelstein	chirelstein	PROPN
cblr-2960	106	5	&	&	CCONJ
cblr-2960	106	6	lawrence	lawrence	PROPN
cblr-2960	106	7	a.	a.	PROPN
cblr-2960	106	8	zelenak	zelenak	PROPN
cblr-2960	106	9	,	,	PUNCT
cblr-2960	106	10	essay	essay	NOUN
cblr-2960	106	11	:	:	PUNCT
cblr-2960	106	12	tax	tax	NOUN
cblr-2960	106	13	shelters	shelter	NOUN
cblr-2960	106	14	and	and	CCONJ
cblr-2960	106	15	the	the	DET
cblr-2960	106	16	search	search	NOUN
cblr-2960	106	17	for	for	ADP
cblr-2960	106	18	a	a	DET
cblr-2960	106	19	silver	silver	ADJ
cblr-2960	106	20	bullet	bullet	NOUN
cblr-2960	106	21	,	,	PUNCT
cblr-2960	106	22	105	105	NUM
cblr-2960	106	23	colum	colum	NOUN
cblr-2960	106	24	.	.	PUNCT
cblr-2960	107	1	l.	l.	PROPN
cblr-2960	107	2	rev	rev	PROPN
cblr-2960	107	3	.	.	PROPN
cblr-2960	107	4	1939	1939	NUM
cblr-2960	107	5	,	,	PUNCT
cblr-2960	107	6	1942	1942	NUM
cblr-2960	107	7	(	(	PUNCT
cblr-2960	107	8	2005	2005	NUM
cblr-2960	107	9	)	)	PUNCT
cblr-2960	107	10	.	.	PUNCT
cblr-2960	108	1	[	[	X
cblr-2960	108	2	vol	vol	NOUN
cblr-2960	108	3	.	.	NOUN
cblr-2960	108	4	2008	2008	NUM
cblr-2960	108	5	job	job	NOUN
cblr-2960	108	6	well	well	ADV
cblr-2960	108	7	done	do	VERB
cblr-2960	108	8	as	as	ADP
cblr-2960	108	9	a	a	DET
cblr-2960	108	10	tax	tax	NOUN
cblr-2960	108	11	avoidance	avoidance	NOUN
cblr-2960	108	12	mechanism	mechanism	NOUN
cblr-2960	108	13	.	.	PUNCT
cblr-2960	109	1	suppose	suppose	VERB
cblr-2960	109	2	b	b	NOUN
cblr-2960	109	3	wants	want	VERB
cblr-2960	109	4	to	to	PART
cblr-2960	109	5	invest	invest	VERB
cblr-2960	109	6	in	in	ADP
cblr-2960	109	7	a	a	DET
cblr-2960	109	8	hedge	hedge	NOUN
cblr-2960	109	9	fund	fund	NOUN
cblr-2960	109	10	interest	interest	NOUN
cblr-2960	109	11	that	that	PRON
cblr-2960	109	12	will	will	AUX
cblr-2960	109	13	generate	generate	VERB
cblr-2960	109	14	$	$	SYM
cblr-2960	109	15	100,000	100,000	NUM
cblr-2960	109	16	of	of	ADP
cblr-2960	109	17	ordinary	ordinary	ADJ
cblr-2960	109	18	income	income	NOUN
cblr-2960	109	19	this	this	DET
cblr-2960	109	20	year	year	NOUN
cblr-2960	109	21	.	.	PUNCT
cblr-2960	110	1	if	if	SCONJ
cblr-2960	110	2	b	b	NOUN
cblr-2960	110	3	invests	invest	NOUN
cblr-2960	110	4	in	in	ADP
cblr-2960	110	5	the	the	DET
cblr-2960	110	6	hedge	hedge	NOUN
cblr-2960	110	7	fund	fund	NOUN
cblr-2960	110	8	directly	directly	ADV
cblr-2960	110	9	,	,	PUNCT
cblr-2960	110	10	the	the	DET
cblr-2960	110	11	accrued	accrue	VERB
cblr-2960	110	12	interest	interest	NOUN
cblr-2960	110	13	may	may	AUX
cblr-2960	110	14	be	be	AUX
cblr-2960	110	15	taxed	tax	VERB
cblr-2960	110	16	either	either	CCONJ
cblr-2960	110	17	at	at	ADP
cblr-2960	110	18	the	the	DET
cblr-2960	110	19	35	35	NUM
cblr-2960	110	20	%	%	NOUN
cblr-2960	110	21	ordinary	ordinary	ADJ
cblr-2960	110	22	income	income	NOUN
cblr-2960	110	23	tax	tax	NOUN
cblr-2960	110	24	rate34	rate34	NOUN
cblr-2960	110	25	or	or	CCONJ
cblr-2960	110	26	the	the	DET
cblr-2960	110	27	more	more	ADV
cblr-2960	110	28	forgiving	forgiving	ADJ
cblr-2960	110	29	15	15	NUM
cblr-2960	110	30	%	%	NOUN
cblr-2960	110	31	long	long	ADJ
cblr-2960	110	32	term	term	NOUN
cblr-2960	110	33	capital	capital	NOUN
cblr-2960	110	34	gain	gain	NOUN
cblr-2960	110	35	rate35	rate35	VERB
cblr-2960	110	36	subjecting	subject	VERB
cblr-2960	110	37	b	b	NOUN
cblr-2960	110	38	to	to	ADP
cblr-2960	110	39	a	a	DET
cblr-2960	110	40	current	current	ADJ
cblr-2960	110	41	tax	tax	NOUN
cblr-2960	110	42	of	of	ADP
cblr-2960	110	43	$	$	SYM
cblr-2960	110	44	35,000	35,000	NUM
cblr-2960	110	45	or	or	CCONJ
cblr-2960	110	46	a	a	DET
cblr-2960	110	47	capital	capital	NOUN
cblr-2960	110	48	gain	gain	NOUN
cblr-2960	110	49	tax	tax	NOUN
cblr-2960	110	50	of	of	ADP
cblr-2960	110	51	$	$	SYM
cblr-2960	110	52	15,000	15,000	NUM
cblr-2960	110	53	.	.	PUNCT
cblr-2960	111	1	in	in	ADP
cblr-2960	111	2	contrast	contrast	NOUN
cblr-2960	111	3	,	,	PUNCT
cblr-2960	111	4	if	if	SCONJ
cblr-2960	111	5	b	b	X
cblr-2960	111	6	instead	instead	ADV
cblr-2960	111	7	purchases	purchase	VERB
cblr-2960	111	8	a	a	DET
cblr-2960	111	9	private	private	ADJ
cblr-2960	111	10	placement	placement	NOUN
cblr-2960	111	11	life	life	NOUN
cblr-2960	111	12	insurance	insurance	NOUN
cblr-2960	111	13	contract	contract	NOUN
cblr-2960	111	14	in	in	ADP
cblr-2960	111	15	which	which	PRON
cblr-2960	111	16	a	a	DET
cblr-2960	111	17	portion	portion	NOUN
cblr-2960	111	18	of	of	ADP
cblr-2960	111	19	the	the	DET
cblr-2960	111	20	premium	premium	NOUN
cblr-2960	111	21	payment	payment	NOUN
cblr-2960	111	22	is	be	AUX
cblr-2960	111	23	invested	invest	VERB
cblr-2960	111	24	in	in	ADP
cblr-2960	111	25	the	the	DET
cblr-2960	111	26	underlying	underlying	ADJ
cblr-2960	111	27	hedge	hedge	NOUN
cblr-2960	111	28	fund	fund	NOUN
cblr-2960	111	29	,	,	PUNCT
cblr-2960	111	30	the	the	DET
cblr-2960	111	31	$	$	SYM
cblr-2960	111	32	100,000	100,000	NUM
cblr-2960	111	33	of	of	ADP
cblr-2960	111	34	gain	gain	NOUN
cblr-2960	111	35	will	will	AUX
cblr-2960	111	36	accrue	accrue	VERB
cblr-2960	111	37	in	in	ADP
cblr-2960	111	38	the	the	DET
cblr-2960	111	39	life	life	NOUN
cblr-2960	111	40	insurance	insurance	NOUN
cblr-2960	111	41	policy	policy	NOUN
cblr-2960	111	42	tax	tax	NOUN
cblr-2960	111	43	-	-	PUNCT
cblr-2960	111	44	free.3	free.3	VERB
cblr-2960	111	45	the	the	DET
cblr-2960	111	46	irs	irs	PROPN
cblr-2960	111	47	also	also	ADV
cblr-2960	111	48	has	have	VERB
cblr-2960	111	49	a	a	DET
cblr-2960	111	50	significant	significant	ADJ
cblr-2960	111	51	stake	stake	NOUN
cblr-2960	111	52	in	in	ADP
cblr-2960	111	53	preventing	prevent	VERB
cblr-2960	111	54	taxpayers	taxpayer	NOUN
cblr-2960	111	55	from	from	ADP
cblr-2960	111	56	avoiding	avoid	VERB
cblr-2960	111	57	taxes	taxis	NOUN
cblr-2960	111	58	on	on	ADP
cblr-2960	111	59	their	their	PRON
cblr-2960	111	60	hedge	hedge	NOUN
cblr-2960	111	61	fund	fund	NOUN
cblr-2960	111	62	gains	gain	NOUN
cblr-2960	111	63	.	.	PUNCT
cblr-2960	112	1	as	as	ADP
cblr-2960	112	2	of	of	ADP
cblr-2960	112	3	the	the	DET
cblr-2960	112	4	summer	summer	NOUN
cblr-2960	112	5	of	of	ADP
cblr-2960	112	6	2006	2006	NUM
cblr-2960	112	7	,	,	PUNCT
cblr-2960	112	8	the	the	DET
cblr-2960	112	9	total	total	ADJ
cblr-2960	112	10	amount	amount	NOUN
cblr-2960	112	11	invested	invest	VERB
cblr-2960	112	12	in	in	ADP
cblr-2960	112	13	hedge	hedge	NOUN
cblr-2960	112	14	funds	fund	NOUN
cblr-2960	112	15	was	be	AUX
cblr-2960	112	16	approximately	approximately	ADV
cblr-2960	112	17	$	$	SYM
cblr-2960	112	18	1.23	1.23	NUM
cblr-2960	112	19	trillion	trillion	NUM
cblr-2960	112	20	.	.	PUNCT
cblr-2960	112	21	7	7	NUM
cblr-2960	112	22	with	with	ADP
cblr-2960	112	23	$	$	SYM
cblr-2960	112	24	1.23	1.23	NUM
cblr-2960	112	25	trillion	trillion	NUM
cblr-2960	112	26	invested	invest	VERB
cblr-2960	112	27	in	in	ADP
cblr-2960	112	28	hedge	hedge	NOUN
cblr-2960	112	29	funds	fund	NOUN
cblr-2960	112	30	and	and	CCONJ
cblr-2960	112	31	assuming	assume	VERB
cblr-2960	112	32	an	an	DET
cblr-2960	112	33	11	11	NUM
cblr-2960	112	34	%	%	NOUN
cblr-2960	112	35	annual	annual	ADJ
cblr-2960	112	36	return,38	return,38	NOUN
cblr-2960	112	37	investors	investor	NOUN
cblr-2960	112	38	paying	pay	VERB
cblr-2960	112	39	tax	tax	NOUN
cblr-2960	112	40	at	at	ADP
cblr-2960	112	41	the	the	DET
cblr-2960	112	42	15	15	NUM
cblr-2960	112	43	%	%	NOUN
cblr-2960	112	44	long	long	ADJ
cblr-2960	112	45	term	term	NOUN
cblr-2960	112	46	capital	capital	NOUN
cblr-2960	112	47	gain	gain	NOUN
cblr-2960	112	48	rate	rate	NOUN
cblr-2960	112	49	are	be	AUX
cblr-2960	112	50	collectively	collectively	ADV
cblr-2960	112	51	paying	pay	VERB
cblr-2960	112	52	just	just	ADV
cblr-2960	112	53	under	under	ADP
cblr-2960	112	54	$	$	SYM
cblr-2960	112	55	20	20	NUM
cblr-2960	112	56	billion	billion	NUM
cblr-2960	112	57	in	in	ADP
cblr-2960	112	58	taxes	taxis	NOUN
cblr-2960	112	59	each	each	DET
cblr-2960	112	60	year	year	NOUN
cblr-2960	112	61	.	.	PUNCT
cblr-2960	113	1	9	9	NUM
cblr-2960	113	2	therefore	therefore	ADV
cblr-2960	113	3	,	,	PUNCT
cblr-2960	113	4	if	if	SCONJ
cblr-2960	113	5	all	all	DET
cblr-2960	113	6	investors	investor	NOUN
cblr-2960	113	7	were	be	AUX
cblr-2960	113	8	using	use	VERB
cblr-2960	113	9	private	private	ADJ
cblr-2960	113	10	placement	placement	NOUN
cblr-2960	113	11	life	life	NOUN
cblr-2960	113	12	insurance	insurance	NOUN
cblr-2960	113	13	contracts	contract	NOUN
cblr-2960	113	14	,	,	PUNCT
cblr-2960	113	15	the	the	DET
cblr-2960	113	16	government	government	NOUN
cblr-2960	113	17	would	would	AUX
cblr-2960	113	18	lose	lose	VERB
cblr-2960	113	19	$	$	SYM
cblr-2960	113	20	20	20	NUM
cblr-2960	113	21	billion	billion	NUM
cblr-2960	113	22	in	in	ADP
cblr-2960	113	23	revenue	revenue	NOUN
cblr-2960	113	24	each	each	DET
cblr-2960	113	25	year	year	NOUN
cblr-2960	113	26	.	.	PUNCT
cblr-2960	114	1	according	accord	VERB
cblr-2960	114	2	to	to	ADP
cblr-2960	114	3	the	the	DET
cblr-2960	114	4	internal	internal	ADJ
cblr-2960	114	5	revenue	revenue	NOUN
cblr-2960	114	6	service	service	NOUN
cblr-2960	114	7	,	,	PUNCT
cblr-2960	114	8	the	the	DET
cblr-2960	114	9	individual	individual	ADJ
cblr-2960	114	10	income	income	NOUN
cblr-2960	114	11	tax	tax	NOUN
cblr-2960	114	12	revenue	revenue	NOUN
cblr-2960	114	13	for	for	ADP
cblr-2960	114	14	the	the	DET
cblr-2960	114	15	national	national	ADJ
cblr-2960	114	16	government	government	NOUN
cblr-2960	114	17	was	be	AUX
cblr-2960	114	18	$	$	SYM
cblr-2960	114	19	1.24	1.24	NUM
cblr-2960	114	20	trillion	trillion	NUM
cblr-2960	114	21	for	for	ADP
cblr-2960	114	22	the	the	DET
cblr-2960	114	23	2006	2006	NUM
cblr-2960	114	24	i.r.c	i.r.c	NOUN
cblr-2960	114	25	.	.	PUNCT
cblr-2960	115	1	§	§	PROPN
cblr-2960	115	2	1	1	NUM
cblr-2960	115	3	(	(	PUNCT
cblr-2960	115	4	imposing	impose	VERB
cblr-2960	115	5	tax	tax	NOUN
cblr-2960	115	6	based	base	VERB
cblr-2960	115	7	on	on	ADP
cblr-2960	115	8	specific	specific	ADJ
cblr-2960	115	9	thresholds	threshold	NOUN
cblr-2960	115	10	of	of	ADP
cblr-2960	115	11	taxable	taxable	ADJ
cblr-2960	115	12	income	income	NOUN
cblr-2960	115	13	within	within	ADP
cblr-2960	115	14	a	a	DET
cblr-2960	115	15	particular	particular	ADJ
cblr-2960	115	16	calendar	calendar	NOUN
cblr-2960	115	17	year	year	NOUN
cblr-2960	115	18	.	.	PUNCT
cblr-2960	116	1	for	for	ADP
cblr-2960	116	2	taxpayers	taxpayer	NOUN
cblr-2960	116	3	in	in	ADP
cblr-2960	116	4	the	the	DET
cblr-2960	116	5	highest	high	ADJ
cblr-2960	116	6	tax	tax	NOUN
cblr-2960	116	7	bracket	bracket	NOUN
cblr-2960	116	8	,	,	PUNCT
cblr-2960	116	9	ordinary	ordinary	ADJ
cblr-2960	116	10	income	income	NOUN
cblr-2960	116	11	for	for	ADP
cblr-2960	116	12	the	the	DET
cblr-2960	116	13	year	year	NOUN
cblr-2960	116	14	will	will	AUX
cblr-2960	116	15	be	be	AUX
cblr-2960	116	16	taxed	tax	VERB
cblr-2960	116	17	at	at	ADP
cblr-2960	116	18	35	35	NUM
cblr-2960	116	19	%	%	NOUN
cblr-2960	116	20	)	)	PUNCT
cblr-2960	116	21	.	.	PUNCT
cblr-2960	117	1	35	35	NUM
cblr-2960	117	2	i.r.c	i.r.c	NOUN
cblr-2960	117	3	.	.	PUNCT
cblr-2960	118	1	§	§	PROPN
cblr-2960	118	2	1(h	1(h	NUM
cblr-2960	118	3	)	)	PUNCT
cblr-2960	118	4	(	(	PUNCT
cblr-2960	118	5	imposing	impose	VERB
cblr-2960	118	6	a	a	DET
cblr-2960	118	7	15	15	NUM
cblr-2960	118	8	%	%	NOUN
cblr-2960	118	9	tax	tax	NOUN
cblr-2960	118	10	on	on	ADP
cblr-2960	118	11	adjusted	adjust	VERB
cblr-2960	118	12	net	net	ADJ
cblr-2960	118	13	capital	capital	NOUN
cblr-2960	118	14	gain	gain	NOUN
cblr-2960	118	15	)	)	PUNCT
cblr-2960	118	16	;	;	PUNCT
cblr-2960	118	17	i.r.c	i.r.c	NOUN
cblr-2960	118	18	§	§	PROPN
cblr-2960	118	19	1222	1222	NUM
cblr-2960	118	20	(	(	PUNCT
cblr-2960	118	21	defining	define	VERB
cblr-2960	118	22	long	long	ADJ
cblr-2960	118	23	-	-	PUNCT
cblr-2960	118	24	term	term	NOUN
cblr-2960	118	25	capital	capital	NOUN
cblr-2960	118	26	gains	gain	NOUN
cblr-2960	118	27	as	as	ADP
cblr-2960	118	28	"	"	PUNCT
cblr-2960	118	29	gains	gain	NOUN
cblr-2960	118	30	from	from	ADP
cblr-2960	118	31	the	the	DET
cblr-2960	118	32	sale	sale	NOUN
cblr-2960	118	33	or	or	CCONJ
cblr-2960	118	34	exchange	exchange	NOUN
cblr-2960	118	35	of	of	ADP
cblr-2960	118	36	a	a	DET
cblr-2960	118	37	capital	capital	NOUN
cblr-2960	118	38	asset	asset	NOUN
cblr-2960	118	39	held	hold	VERB
cblr-2960	118	40	for	for	ADP
cblr-2960	118	41	more	more	ADJ
cblr-2960	118	42	than	than	ADP
cblr-2960	118	43	1	1	NUM
cblr-2960	118	44	year	year	NOUN
cblr-2960	118	45	"	"	PUNCT
cblr-2960	118	46	)	)	PUNCT
cblr-2960	118	47	.	.	PUNCT
cblr-2960	119	1	36	36	NUM
cblr-2960	119	2	see	see	VERB
cblr-2960	119	3	i.r.c	i.r.c	NOUN
cblr-2960	119	4	.	.	PUNCT
cblr-2960	120	1	§	§	PROPN
cblr-2960	120	2	72	72	NUM
cblr-2960	120	3	.	.	PUNCT
cblr-2960	120	4	17	17	NUM
cblr-2960	120	5	see	see	VERB
cblr-2960	120	6	silverman	silverman	NOUN
cblr-2960	120	7	,	,	PUNCT
cblr-2960	120	8	supra	supra	PROPN
cblr-2960	120	9	note	note	PROPN
cblr-2960	120	10	11	11	NUM
cblr-2960	120	11	.	.	PUNCT
cblr-2960	120	12	38	38	NUM
cblr-2960	120	13	according	accord	VERB
cblr-2960	120	14	to	to	ADP
cblr-2960	120	15	the	the	DET
cblr-2960	120	16	cs	cs	PROPN
cblr-2960	120	17	/	/	SYM
cblr-2960	120	18	tremont	tremont	PROPN
cblr-2960	120	19	hedge	hedge	PROPN
cblr-2960	120	20	fund	fund	PROPN
cblr-2960	120	21	index	index	PROPN
cblr-2960	120	22	,	,	PUNCT
cblr-2960	120	23	the	the	DET
cblr-2960	120	24	annual	annual	ADJ
cblr-2960	120	25	return	return	NOUN
cblr-2960	120	26	over	over	ADP
cblr-2960	120	27	the	the	DET
cblr-2960	120	28	period	period	NOUN
cblr-2960	120	29	from	from	ADP
cblr-2960	120	30	january	january	PROPN
cblr-2960	120	31	1994	1994	NUM
cblr-2960	120	32	to	to	ADP
cblr-2960	120	33	december	december	PROPN
cblr-2960	120	34	2005	2005	NUM
cblr-2960	120	35	was	be	AUX
cblr-2960	120	36	10.69	10.69	NUM
cblr-2960	120	37	%	%	NOUN
cblr-2960	120	38	.	.	PUNCT
cblr-2960	121	1	the	the	DET
cblr-2960	121	2	cs	cs	PROPN
cblr-2960	121	3	/	/	SYM
cblr-2960	121	4	tremont	tremont	PROPN
cblr-2960	121	5	hedge	hedge	PROPN
cblr-2960	121	6	fund	fund	PROPN
cblr-2960	121	7	index	index	NOUN
cblr-2960	121	8	is	be	AUX
cblr-2960	121	9	a	a	DET
cblr-2960	121	10	capitalization	capitalization	NOUN
cblr-2960	121	11	-	-	PUNCT
cblr-2960	121	12	weighted	weight	VERB
cblr-2960	121	13	index	index	NOUN
cblr-2960	121	14	,	,	PUNCT
cblr-2960	121	15	and	and	CCONJ
cblr-2960	121	16	uses	use	VERB
cblr-2960	121	17	only	only	ADJ
cblr-2960	121	18	funds	fund	NOUN
cblr-2960	121	19	that	that	PRON
cblr-2960	121	20	have	have	VERB
cblr-2960	121	21	at	at	ADV
cblr-2960	121	22	least	least	ADV
cblr-2960	121	23	$	$	SYM
cblr-2960	121	24	10	10	NUM
cblr-2960	121	25	million	million	NUM
cblr-2960	121	26	of	of	ADP
cblr-2960	121	27	assets	asset	NOUN
cblr-2960	121	28	and	and	CCONJ
cblr-2960	121	29	can	can	AUX
cblr-2960	121	30	provide	provide	VERB
cblr-2960	121	31	audited	audit	VERB
cblr-2960	121	32	performance	performance	NOUN
cblr-2960	121	33	figures	figure	NOUN
cblr-2960	121	34	.	.	PUNCT
cblr-2960	122	1	lhabitant	lhabitant	PROPN
cblr-2960	122	2	,	,	PUNCT
cblr-2960	122	3	supra	supra	PROPN
cblr-2960	122	4	note	note	PROPN
cblr-2960	122	5	1	1	NUM
cblr-2960	122	6	,	,	PUNCT
cblr-2960	122	7	at	at	ADP
cblr-2960	122	8	518	518	NUM
cblr-2960	122	9	.	.	PUNCT
cblr-2960	122	10	39	39	NUM
cblr-2960	122	11	see	see	NOUN
cblr-2960	122	12	i.r.c	i.r.c	NOUN
cblr-2960	122	13	.	.	PUNCT
cblr-2960	123	1	§	§	PROPN
cblr-2960	123	2	§	§	PROPN
cblr-2960	123	3	1(h	1(h	NUM
cblr-2960	123	4	)	)	PUNCT
cblr-2960	123	5	,	,	PUNCT
cblr-2960	123	6	1222	1222	NUM
cblr-2960	123	7	.	.	PUNCT
cblr-2960	124	1	no	no	INTJ
cblr-2960	124	2	.	.	PUNCT
cblr-2960	125	1	2:694	2:694	NUM
cblr-2960	125	2	]	]	X
cblr-2960	125	3	fiscal	fiscal	ADJ
cblr-2960	125	4	year.4	year.4	PROPN
cblr-2960	125	5	"	"	PUNCT
cblr-2960	125	6	therefore	therefore	ADV
cblr-2960	125	7	,	,	PUNCT
cblr-2960	125	8	the	the	DET
cblr-2960	125	9	loss	loss	NOUN
cblr-2960	125	10	of	of	ADP
cblr-2960	125	11	$	$	SYM
cblr-2960	125	12	20	20	NUM
cblr-2960	125	13	billion	billion	NUM
cblr-2960	125	14	would	would	AUX
cblr-2960	125	15	account	account	VERB
cblr-2960	125	16	for	for	ADP
cblr-2960	125	17	more	more	ADJ
cblr-2960	125	18	than	than	ADP
cblr-2960	125	19	a	a	DET
cblr-2960	125	20	1.5	1.5	NUM
cblr-2960	125	21	%	%	NOUN
cblr-2960	125	22	drop	drop	NOUN
cblr-2960	125	23	in	in	ADP
cblr-2960	125	24	individual	individual	ADJ
cblr-2960	125	25	income	income	NOUN
cblr-2960	125	26	tax	tax	NOUN
cblr-2960	125	27	revenue	revenue	NOUN
cblr-2960	125	28	each	each	DET
cblr-2960	125	29	year	year	NOUN
cblr-2960	125	30	.	.	PUNCT
cblr-2960	126	1	iii	iii	X
cblr-2960	126	2	.	.	PUNCT
cblr-2960	126	3	current	current	ADJ
cblr-2960	126	4	law	law	NOUN
cblr-2960	126	5	recently	recently	ADV
cblr-2960	126	6	,	,	PUNCT
cblr-2960	126	7	the	the	DET
cblr-2960	126	8	irs	irs	PROPN
cblr-2960	126	9	released	release	VERB
cblr-2960	126	10	rulings	ruling	NOUN
cblr-2960	126	11	and	and	CCONJ
cblr-2960	126	12	changes	change	NOUN
cblr-2960	126	13	in	in	ADP
cblr-2960	126	14	regulations	regulation	NOUN
cblr-2960	126	15	regarding	regard	VERB
cblr-2960	126	16	the	the	DET
cblr-2960	126	17	use	use	NOUN
cblr-2960	126	18	of	of	ADP
cblr-2960	126	19	private	private	ADJ
cblr-2960	126	20	placement	placement	NOUN
cblr-2960	126	21	life	life	NOUN
cblr-2960	126	22	insurance	insurance	NOUN
cblr-2960	126	23	policies	policy	NOUN
cblr-2960	126	24	as	as	ADP
cblr-2960	126	25	a	a	DET
cblr-2960	126	26	mechanism	mechanism	NOUN
cblr-2960	126	27	to	to	PART
cblr-2960	126	28	avoid	avoid	VERB
cblr-2960	126	29	the	the	DET
cblr-2960	126	30	tax	tax	NOUN
cblr-2960	126	31	imposed	impose	VERB
cblr-2960	126	32	on	on	ADP
cblr-2960	126	33	hedge	hedge	NOUN
cblr-2960	126	34	fund	fund	NOUN
cblr-2960	126	35	gains.41	gains.41	NOUN
cblr-2960	126	36	these	these	DET
cblr-2960	126	37	rulings	ruling	NOUN
cblr-2960	126	38	have	have	AUX
cblr-2960	126	39	not	not	PART
cblr-2960	126	40	completely	completely	ADV
cblr-2960	126	41	prohibited	prohibit	VERB
cblr-2960	126	42	such	such	ADJ
cblr-2960	126	43	products	product	NOUN
cblr-2960	126	44	from	from	ADP
cblr-2960	126	45	being	be	AUX
cblr-2960	126	46	offered	offer	VERB
cblr-2960	126	47	,	,	PUNCT
cblr-2960	126	48	but	but	CCONJ
cblr-2960	126	49	instead	instead	ADV
cblr-2960	126	50	allow	allow	VERB
cblr-2960	126	51	investors	investor	NOUN
cblr-2960	126	52	to	to	PART
cblr-2960	126	53	purchase	purchase	VERB
cblr-2960	126	54	such	such	ADJ
cblr-2960	126	55	policies	policy	NOUN
cblr-2960	126	56	,	,	PUNCT
cblr-2960	126	57	if	if	SCONJ
cblr-2960	126	58	the	the	DET
cblr-2960	126	59	product	product	NOUN
cblr-2960	126	60	remains	remain	VERB
cblr-2960	126	61	compliant	compliant	ADJ
cblr-2960	126	62	with	with	ADP
cblr-2960	126	63	the	the	DET
cblr-2960	126	64	rulings	ruling	NOUN
cblr-2960	126	65	and	and	CCONJ
cblr-2960	126	66	regulations.42	regulations.42	NOUN
cblr-2960	126	67	investing	invest	VERB
cblr-2960	126	68	in	in	ADP
cblr-2960	126	69	hedge	hedge	NOUN
cblr-2960	126	70	funds	fund	NOUN
cblr-2960	126	71	through	through	ADP
cblr-2960	126	72	private	private	ADJ
cblr-2960	126	73	placement	placement	NOUN
cblr-2960	126	74	life	life	NOUN
cblr-2960	126	75	insurance	insurance	NOUN
cblr-2960	126	76	remains	remain	VERB
cblr-2960	126	77	a	a	DET
cblr-2960	126	78	viable	viable	ADJ
cblr-2960	126	79	planning	planning	NOUN
cblr-2960	126	80	tool	tool	NOUN
cblr-2960	126	81	,	,	PUNCT
cblr-2960	126	82	and	and	CCONJ
cblr-2960	126	83	the	the	DET
cblr-2960	126	84	recent	recent	ADJ
cblr-2960	126	85	developments	development	NOUN
cblr-2960	126	86	in	in	ADP
cblr-2960	126	87	the	the	DET
cblr-2960	126	88	law	law	NOUN
cblr-2960	126	89	affect	affect	VERB
cblr-2960	126	90	only	only	ADV
cblr-2960	126	91	the	the	DET
cblr-2960	126	92	design	design	NOUN
cblr-2960	126	93	of	of	ADP
cblr-2960	126	94	these	these	DET
cblr-2960	126	95	products.43	products.43	NOUN
cblr-2960	126	96	the	the	DET
cblr-2960	126	97	question	question	NOUN
cblr-2960	126	98	remains	remain	VERB
cblr-2960	126	99	,	,	PUNCT
cblr-2960	126	100	if	if	SCONJ
cblr-2960	126	101	sophisticated	sophisticated	ADJ
cblr-2960	126	102	taxpayers	taxpayer	NOUN
cblr-2960	126	103	can	can	AUX
cblr-2960	126	104	continue	continue	VERB
cblr-2960	126	105	to	to	PART
cblr-2960	126	106	use	use	VERB
cblr-2960	126	107	life	life	NOUN
cblr-2960	126	108	insurance	insurance	NOUN
cblr-2960	126	109	products	product	NOUN
cblr-2960	126	110	as	as	ADP
cblr-2960	126	111	a	a	DET
cblr-2960	126	112	tax	tax	NOUN
cblr-2960	126	113	shelter	shelter	NOUN
cblr-2960	126	114	for	for	ADP
cblr-2960	126	115	hedge	hedge	NOUN
cblr-2960	126	116	fund	fund	NOUN
cblr-2960	126	117	gains	gain	NOUN
cblr-2960	126	118	,	,	PUNCT
cblr-2960	126	119	are	be	AUX
cblr-2960	126	120	the	the	DET
cblr-2960	126	121	anti	anti	ADJ
cblr-2960	126	122	-	-	ADJ
cblr-2960	126	123	avoidance	avoidance	ADJ
cblr-2960	126	124	regulations	regulation	NOUN
cblr-2960	126	125	to	to	PART
cblr-2960	126	126	stop	stop	VERB
cblr-2960	126	127	such	such	ADJ
cblr-2960	126	128	insurance	insurance	NOUN
cblr-2960	126	129	wrappers	wrapper	NOUN
cblr-2960	126	130	an	an	DET
cblr-2960	126	131	effective	effective	ADJ
cblr-2960	126	132	tax	tax	NOUN
cblr-2960	126	133	reform	reform	NOUN
cblr-2960	126	134	measure	measure	NOUN
cblr-2960	126	135	?	?	PUNCT
cblr-2960	127	1	a.	a.	NOUN
cblr-2960	127	2	diversification	diversification	NOUN
cblr-2960	127	3	requirement	requirement	NOUN
cblr-2960	127	4	on	on	ADP
cblr-2960	127	5	july	july	PROPN
cblr-2960	127	6	18	18	NUM
cblr-2960	127	7	,	,	PUNCT
cblr-2960	127	8	1984	1984	NUM
cblr-2960	127	9	,	,	PUNCT
cblr-2960	127	10	congress	congress	PROPN
cblr-2960	127	11	enacted	enact	VERB
cblr-2960	127	12	the	the	DET
cblr-2960	127	13	diversification	diversification	NOUN
cblr-2960	127	14	requirement	requirement	NOUN
cblr-2960	127	15	of	of	ADP
cblr-2960	127	16	section	section	NOUN
cblr-2960	127	17	817(h	817(h	PROPN
cblr-2960	127	18	)	)	PUNCT
cblr-2960	127	19	to	to	PART
cblr-2960	127	20	reduce	reduce	VERB
cblr-2960	127	21	the	the	DET
cblr-2960	127	22	use	use	NOUN
cblr-2960	127	23	of	of	ADP
cblr-2960	127	24	life	life	NOUN
cblr-2960	127	25	"	"	PUNCT
cblr-2960	127	26	internal	internal	ADJ
cblr-2960	127	27	revenue	revenue	NOUN
cblr-2960	127	28	serv	serv	X
cblr-2960	127	29	.	.	PUNCT
cblr-2960	128	1	,	,	PUNCT
cblr-2960	128	2	tax	tax	NOUN
cblr-2960	128	3	stats	stat	NOUN
cblr-2960	128	4	at	at	ADP
cblr-2960	128	5	a	a	DET
cblr-2960	128	6	glance	glance	NOUN
cblr-2960	128	7	,	,	PUNCT
cblr-2960	128	8	http://www.irs.gov/taxstats/article/0,,id=102886,00.html	http://www.irs.gov/taxstats/article/0,,id=102886,00.html	PROPN
cblr-2960	128	9	(	(	PUNCT
cblr-2960	128	10	last	last	ADV
cblr-2960	128	11	visited	visit	VERB
cblr-2960	128	12	feb	feb	PROPN
cblr-2960	128	13	.	.	PROPN
cblr-2960	128	14	25	25	NUM
cblr-2960	128	15	,	,	PUNCT
cblr-2960	128	16	2008	2008	NUM
cblr-2960	128	17	)	)	PUNCT
cblr-2960	128	18	.	.	PUNCT
cblr-2960	129	1	41	41	NUM
cblr-2960	129	2	see	see	VERB
cblr-2960	129	3	i.r.s	i.r.s	NOUN
cblr-2960	129	4	.	.	PUNCT
cblr-2960	130	1	priv	priv	PROPN
cblr-2960	130	2	.	.	PUNCT
cblr-2960	131	1	ltr	ltr	PROPN
cblr-2960	131	2	.	.	PUNCT
cblr-2960	131	3	rul	rul	PROPN
cblr-2960	131	4	.	.	PUNCT
cblr-2960	131	5	2002	2002	NUM
cblr-2960	131	6	-	-	SYM
cblr-2960	131	7	44	44	NUM
cblr-2960	131	8	-	-	PUNCT
cblr-2960	131	9	001	001	NUM
cblr-2960	131	10	(	(	PUNCT
cblr-2960	131	11	may	may	PROPN
cblr-2960	131	12	2	2	NUM
cblr-2960	131	13	,	,	PUNCT
cblr-2960	131	14	2002	2002	NUM
cblr-2960	131	15	)	)	PUNCT
cblr-2960	131	16	;	;	PUNCT
cblr-2960	131	17	rev	rev	PROPN
cblr-2960	131	18	.	.	PROPN
cblr-2960	131	19	rul	rul	PROPN
cblr-2960	131	20	.	.	PUNCT
cblr-2960	131	21	200392	200392	NUM
cblr-2960	131	22	;	;	PUNCT
cblr-2960	131	23	rev	rev	PROPN
cblr-2960	131	24	.	.	PROPN
cblr-2960	131	25	rul	rul	PROPN
cblr-2960	131	26	.	.	PUNCT
cblr-2960	131	27	2003	2003	NUM
cblr-2960	131	28	-	-	SYM
cblr-2960	131	29	91	91	NUM
cblr-2960	131	30	;	;	PUNCT
cblr-2960	131	31	see	see	VERB
cblr-2960	131	32	also	also	ADV
cblr-2960	131	33	internal	internal	ADJ
cblr-2960	131	34	revenue	revenue	NOUN
cblr-2960	131	35	serv	serv	X
cblr-2960	131	36	.	.	PUNCT
cblr-2960	131	37	,	,	PUNCT
cblr-2960	131	38	regs	regs	PROPN
cblr-2960	131	39	target	target	NOUN
cblr-2960	131	40	use	use	NOUN
cblr-2960	131	41	of	of	ADP
cblr-2960	131	42	annuity	annuity	NOUN
cblr-2960	131	43	contracts	contract	NOUN
cblr-2960	131	44	,	,	PUNCT
cblr-2960	131	45	life	life	NOUN
cblr-2960	131	46	insurance	insurance	NOUN
cblr-2960	131	47	as	as	ADP
cblr-2960	131	48	tax	tax	NOUN
cblr-2960	131	49	avoidance	avoidance	NOUN
cblr-2960	131	50	vehicles	vehicle	NOUN
cblr-2960	131	51	,	,	PUNCT
cblr-2960	131	52	2003	2003	NUM
cblr-2960	131	53	tax	tax	NOUN
cblr-2960	131	54	notes	note	VERB
cblr-2960	131	55	146	146	NUM
cblr-2960	131	56	-	-	SYM
cblr-2960	131	57	11	11	NUM
cblr-2960	131	58	(	(	PUNCT
cblr-2960	131	59	2003	2003	NUM
cblr-2960	131	60	)	)	PUNCT
cblr-2960	131	61	(	(	PUNCT
cblr-2960	131	62	announcing	announce	VERB
cblr-2960	131	63	that	that	SCONJ
cblr-2960	131	64	the	the	DET
cblr-2960	131	65	service	service	NOUN
cblr-2960	131	66	has	have	AUX
cblr-2960	131	67	issued	issue	VERB
cblr-2960	131	68	proposed	propose	VERB
cblr-2960	131	69	regulations	regulation	NOUN
cblr-2960	131	70	to	to	PART
cblr-2960	131	71	curb	curb	VERB
cblr-2960	131	72	the	the	DET
cblr-2960	131	73	use	use	NOUN
cblr-2960	131	74	of	of	ADP
cblr-2960	131	75	tax	tax	NOUN
cblr-2960	131	76	-	-	PUNCT
cblr-2960	131	77	preferred	prefer	VERB
cblr-2960	131	78	life	life	NOUN
cblr-2960	131	79	insurance	insurance	NOUN
cblr-2960	131	80	and	and	CCONJ
cblr-2960	131	81	annuity	annuity	NOUN
cblr-2960	131	82	contracts	contract	NOUN
cblr-2960	131	83	for	for	ADP
cblr-2960	131	84	tax	tax	NOUN
cblr-2960	131	85	avoidance	avoidance	NOUN
cblr-2960	131	86	on	on	ADP
cblr-2960	131	87	investment	investment	NOUN
cblr-2960	131	88	earnings	earning	NOUN
cblr-2960	131	89	)	)	PUNCT
cblr-2960	131	90	.	.	PUNCT
cblr-2960	132	1	42	42	NUM
cblr-2960	132	2	david	david	PROPN
cblr-2960	132	3	s.	s.	PROPN
cblr-2960	132	4	neufeld	neufeld	PROPN
cblr-2960	132	5	,	,	PUNCT
cblr-2960	132	6	new	new	ADJ
cblr-2960	132	7	guidance	guidance	NOUN
cblr-2960	132	8	on	on	ADP
cblr-2960	132	9	investor	investor	NOUN
cblr-2960	132	10	control	control	NOUN
cblr-2960	132	11	rule	rule	NOUN
cblr-2960	132	12	:	:	PUNCT
cblr-2960	132	13	road	road	NOUN
cblr-2960	132	14	map	map	NOUN
cblr-2960	132	15	or	or	CCONJ
cblr-2960	132	16	roadblock	roadblock	NOUN
cblr-2960	132	17	?	?	PUNCT
cblr-2960	132	18	,	,	PUNCT
cblr-2960	132	19	100	100	NUM
cblr-2960	132	20	tax	tax	NOUN
cblr-2960	132	21	notes	note	NOUN
cblr-2960	132	22	1191	1191	NUM
cblr-2960	132	23	,	,	PUNCT
cblr-2960	132	24	1191	1191	NUM
cblr-2960	132	25	(	(	PUNCT
cblr-2960	132	26	2003	2003	NUM
cblr-2960	132	27	)	)	PUNCT
cblr-2960	132	28	(	(	PUNCT
cblr-2960	132	29	explaining	explain	VERB
cblr-2960	132	30	that	that	SCONJ
cblr-2960	132	31	the	the	DET
cblr-2960	132	32	recent	recent	ADJ
cblr-2960	132	33	reforms	reform	NOUN
cblr-2960	132	34	delineate	delineate	VERB
cblr-2960	132	35	"	"	PUNCT
cblr-2960	132	36	how	how	SCONJ
cblr-2960	132	37	insurance	insurance	NOUN
cblr-2960	132	38	policies	policy	NOUN
cblr-2960	132	39	can	can	AUX
cblr-2960	132	40	own	own	VERB
cblr-2960	132	41	hedge	hedge	NOUN
cblr-2960	132	42	funds	fund	NOUN
cblr-2960	132	43	and	and	CCONJ
cblr-2960	132	44	who	who	PRON
cblr-2960	132	45	can	can	AUX
cblr-2960	132	46	make	make	VERB
cblr-2960	132	47	investment	investment	NOUN
cblr-2960	132	48	decisions	decision	NOUN
cblr-2960	132	49	"	"	PUNCT
cblr-2960	132	50	)	)	PUNCT
cblr-2960	132	51	.	.	PUNCT
cblr-2960	133	1	43	43	NUM
cblr-2960	134	1	i	i	PRON
cblr-2960	134	2	d.	d.	PROPN
cblr-2960	135	1	[	[	X
cblr-2960	135	2	vol	vol	NOUN
cblr-2960	135	3	.	.	PUNCT
cblr-2960	136	1	2008coluama	2008coluama	NUM
cblr-2960	136	2	b	b	X
cblr-2960	136	3	usiness	usiness	NOUN
cblr-2960	136	4	la	la	PROPN
cblr-2960	136	5	w	w	PROPN
cblr-2960	136	6	re	re	PROPN
cblr-2960	136	7	vie	vie	PROPN
cblr-2960	136	8	w	w	PROPN
cblr-2960	136	9	job	job	NOUN
cblr-2960	136	10	well	well	ADV
cblr-2960	136	11	done	do	VERB
cblr-2960	136	12	insurance	insurance	NOUN
cblr-2960	136	13	policies	policy	NOUN
cblr-2960	136	14	as	as	ADP
cblr-2960	136	15	investment	investment	NOUN
cblr-2960	136	16	vehicles	vehicle	NOUN
cblr-2960	136	17	.	.	PUNCT
cblr-2960	136	18	"	"	PUNCT
cblr-2960	137	1	under	under	ADP
cblr-2960	137	2	section	section	NOUN
cblr-2960	137	3	817(h	817(h	PROPN
cblr-2960	137	4	)	)	PUNCT
cblr-2960	137	5	,	,	PUNCT
cblr-2960	137	6	to	to	PART
cblr-2960	137	7	qualify	qualify	VERB
cblr-2960	137	8	as	as	ADP
cblr-2960	137	9	life	life	NOUN
cblr-2960	137	10	insurance	insurance	NOUN
cblr-2960	137	11	and	and	CCONJ
cblr-2960	137	12	receive	receive	VERB
cblr-2960	137	13	the	the	DET
cblr-2960	137	14	attendant	attendant	ADJ
cblr-2960	137	15	tax	tax	NOUN
cblr-2960	137	16	benefits	benefit	NOUN
cblr-2960	137	17	,	,	PUNCT
cblr-2960	137	18	variable	variable	ADJ
cblr-2960	137	19	life	life	NOUN
cblr-2960	137	20	insurance	insurance	NOUN
cblr-2960	137	21	policies	policy	NOUN
cblr-2960	137	22	must	must	AUX
cblr-2960	137	23	be	be	AUX
cblr-2960	137	24	"	"	PUNCT
cblr-2960	137	25	adequately	adequately	ADV
cblr-2960	137	26	diversified	diversified	ADJ
cblr-2960	137	27	.	.	PUNCT
cblr-2960	138	1	"45	"45	NOUN
cblr-2960	138	2	in	in	ADP
cblr-2960	138	3	its	its	PRON
cblr-2960	138	4	simplest	simple	ADJ
cblr-2960	138	5	form	form	NOUN
cblr-2960	138	6	,	,	PUNCT
cblr-2960	138	7	this	this	PRON
cblr-2960	138	8	means	mean	VERB
cblr-2960	138	9	that	that	SCONJ
cblr-2960	138	10	each	each	DET
cblr-2960	138	11	"	"	PUNCT
cblr-2960	138	12	segregated	segregated	ADJ
cblr-2960	138	13	asset	asset	NOUN
cblr-2960	138	14	account	account	NOUN
cblr-2960	138	15	"	"	PUNCT
cblr-2960	138	16	must	must	AUX
cblr-2960	138	17	contain	contain	VERB
cblr-2960	138	18	at	at	ADV
cblr-2960	138	19	least	least	ADJ
cblr-2960	138	20	five	five	NUM
cblr-2960	138	21	investments	investment	NOUN
cblr-2960	138	22	,	,	PUNCT
cblr-2960	138	23	and	and	CCONJ
cblr-2960	138	24	no	no	DET
cblr-2960	138	25	one	one	NUM
cblr-2960	138	26	investment	investment	NOUN
cblr-2960	138	27	may	may	AUX
cblr-2960	138	28	represent	represent	VERB
cblr-2960	138	29	more	more	ADJ
cblr-2960	138	30	than	than	ADP
cblr-2960	138	31	55	55	NUM
cblr-2960	138	32	%	%	NOUN
cblr-2960	138	33	of	of	ADP
cblr-2960	138	34	the	the	DET
cblr-2960	138	35	value	value	NOUN
cblr-2960	138	36	of	of	ADP
cblr-2960	138	37	a	a	DET
cblr-2960	138	38	separate	separate	ADJ
cblr-2960	138	39	account	account	NOUN
cblr-2960	138	40	's	's	PART
cblr-2960	138	41	assets	asset	NOUN
cblr-2960	138	42	,	,	PUNCT
cblr-2960	138	43	no	no	DET
cblr-2960	138	44	two	two	NUM
cblr-2960	138	45	investments	investment	NOUN
cblr-2960	138	46	may	may	AUX
cblr-2960	138	47	constitute	constitute	VERB
cblr-2960	138	48	more	more	ADJ
cblr-2960	138	49	than	than	ADP
cblr-2960	138	50	70	70	NUM
cblr-2960	138	51	%	%	NOUN
cblr-2960	138	52	,	,	PUNCT
cblr-2960	138	53	no	no	DET
cblr-2960	138	54	three	three	NUM
cblr-2960	138	55	investments	investment	NOUN
cblr-2960	138	56	may	may	AUX
cblr-2960	138	57	comprise	comprise	VERB
cblr-2960	138	58	more	more	ADJ
cblr-2960	138	59	than	than	ADP
cblr-2960	138	60	80	80	NUM
cblr-2960	138	61	%	%	NOUN
cblr-2960	138	62	,	,	PUNCT
cblr-2960	138	63	and	and	CCONJ
cblr-2960	138	64	no	no	DET
cblr-2960	138	65	four	four	NUM
cblr-2960	138	66	investments	investment	NOUN
cblr-2960	138	67	may	may	AUX
cblr-2960	138	68	make	make	VERB
cblr-2960	138	69	up	up	ADP
cblr-2960	138	70	more	more	ADJ
cblr-2960	138	71	than	than	ADP
cblr-2960	138	72	90	90	NUM
cblr-2960	138	73	%	%	NOUN
cblr-2960	138	74	of	of	ADP
cblr-2960	138	75	the	the	DET
cblr-2960	138	76	separate	separate	ADJ
cblr-2960	138	77	account	account	NOUN
cblr-2960	138	78	's	's	PART
cblr-2960	138	79	value.46	value.46	NOUN
cblr-2960	138	80	in	in	ADP
cblr-2960	138	81	the	the	DET
cblr-2960	138	82	case	case	NOUN
cblr-2960	138	83	of	of	ADP
cblr-2960	138	84	a	a	DET
cblr-2960	138	85	nonregistered	nonregistered	ADJ
cblr-2960	138	86	limited	limited	ADJ
cblr-2960	138	87	partnership	partnership	NOUN
cblr-2960	138	88	like	like	ADP
cblr-2960	138	89	a	a	DET
cblr-2960	138	90	hedge	hedge	NOUN
cblr-2960	138	91	fund	fund	NOUN
cblr-2960	138	92	,	,	PUNCT
cblr-2960	138	93	as	as	ADV
cblr-2960	138	94	long	long	ADV
cblr-2960	138	95	as	as	SCONJ
cblr-2960	138	96	only	only	ADJ
cblr-2960	138	97	insurance	insurance	NOUN
cblr-2960	138	98	companies	company	NOUN
cblr-2960	138	99	may	may	AUX
cblr-2960	138	100	invest	invest	VERB
cblr-2960	138	101	in	in	ADP
cblr-2960	138	102	the	the	DET
cblr-2960	138	103	hedge	hedge	NOUN
cblr-2960	138	104	fund	fund	NOUN
cblr-2960	138	105	,	,	PUNCT
cblr-2960	138	106	the	the	DET
cblr-2960	138	107	hedge	hedge	NOUN
cblr-2960	138	108	fund	fund	NOUN
cblr-2960	138	109	can	can	AUX
cblr-2960	138	110	be	be	AUX
cblr-2960	138	111	looked	look	VERB
cblr-2960	138	112	through	through	ADP
cblr-2960	138	113	and	and	CCONJ
cblr-2960	138	114	its	its	PRON
cblr-2960	138	115	underlying	underlie	VERB
cblr-2960	138	116	investments	investment	NOUN
cblr-2960	138	117	counted	count	VERB
cblr-2960	138	118	in	in	ADP
cblr-2960	138	119	computing	compute	VERB
cblr-2960	138	120	diversification.47	diversification.47	PROPN
cblr-2960	138	121	failure	failure	NOUN
cblr-2960	138	122	to	to	PART
cblr-2960	138	123	meet	meet	VERB
cblr-2960	138	124	the	the	DET
cblr-2960	138	125	diversification	diversification	NOUN
cblr-2960	138	126	requirements	requirement	NOUN
cblr-2960	138	127	under	under	ADP
cblr-2960	138	128	section	section	NOUN
cblr-2960	138	129	817(h	817(h	PROPN
cblr-2960	138	130	)	)	PUNCT
cblr-2960	138	131	will	will	AUX
cblr-2960	138	132	result	result	VERB
cblr-2960	138	133	in	in	ADP
cblr-2960	138	134	taxation	taxation	NOUN
cblr-2960	138	135	of	of	ADP
cblr-2960	138	136	the	the	DET
cblr-2960	138	137	cash	cash	NOUN
cblr-2960	138	138	value	value	NOUN
cblr-2960	138	139	accumulation	accumulation	NOUN
cblr-2960	138	140	of	of	ADP
cblr-2960	138	141	the	the	DET
cblr-2960	138	142	life	life	NOUN
cblr-2960	138	143	insurance	insurance	NOUN
cblr-2960	138	144	policy	policy	NOUN
cblr-2960	138	145	as	as	ADP
cblr-2960	138	146	ordinary	ordinary	ADJ
cblr-2960	138	147	income	income	NOUN
cblr-2960	138	148	to	to	ADP
cblr-2960	138	149	the	the	DET
cblr-2960	138	150	policy	policy	NOUN
cblr-2960	138	151	owner.48	owner.48	PROPN
cblr-2960	138	152	b.	b.	PROPN
cblr-2960	138	153	investor	investor	PROPN
cblr-2960	138	154	control	control	PROPN
cblr-2960	138	155	doctrine	doctrine	NOUN
cblr-2960	138	156	before	before	ADP
cblr-2960	138	157	the	the	DET
cblr-2960	138	158	enactment	enactment	NOUN
cblr-2960	138	159	of	of	ADP
cblr-2960	138	160	section	section	NOUN
cblr-2960	138	161	817	817	NUM
cblr-2960	138	162	,	,	PUNCT
cblr-2960	138	163	the	the	DET
cblr-2960	138	164	service	service	NOUN
cblr-2960	138	165	was	be	AUX
cblr-2960	138	166	concerned	concern	VERB
cblr-2960	138	167	that	that	SCONJ
cblr-2960	138	168	taxpayers	taxpayer	NOUN
cblr-2960	138	169	were	be	AUX
cblr-2960	138	170	avoiding	avoid	VERB
cblr-2960	138	171	income	income	NOUN
cblr-2960	138	172	tax	tax	NOUN
cblr-2960	138	173	by	by	ADP
cblr-2960	138	174	wrapping	wrap	VERB
cblr-2960	138	175	their	their	PRON
cblr-2960	138	176	investments	investment	NOUN
cblr-2960	138	177	in	in	ADP
cblr-2960	138	178	certain	certain	ADJ
cblr-2960	138	179	annuity	annuity	NOUN
cblr-2960	138	180	or	or	CCONJ
cblr-2960	138	181	life	life	NOUN
cblr-2960	138	182	insurance	insurance	NOUN
cblr-2960	138	183	contracts.49	contracts.49	ADV
cblr-2960	138	184	in	in	ADP
cblr-2960	138	185	response	response	NOUN
cblr-2960	138	186	,	,	PUNCT
cblr-2960	138	187	the	the	DET
cblr-2960	138	188	tax	tax	NOUN
cblr-2960	138	189	agencies	agency	NOUN
cblr-2960	138	190	released	release	VERB
cblr-2960	138	191	"	"	PUNCT
cblr-2960	138	192	h.r	h.r	PROPN
cblr-2960	138	193	.	.	PROPN
cblr-2960	138	194	conf	conf	PROPN
cblr-2960	138	195	.	.	PUNCT
cblr-2960	139	1	rep	rep	PROPN
cblr-2960	139	2	.	.	PROPN
cblr-2960	139	3	no	no	PROPN
cblr-2960	139	4	.	.	NOUN
cblr-2960	140	1	98	98	NUM
cblr-2960	140	2	-	-	SYM
cblr-2960	140	3	861	861	NUM
cblr-2960	140	4	,	,	PUNCT
cblr-2960	140	5	at	at	ADP
cblr-2960	140	6	1055	1055	NUM
cblr-2960	140	7	(	(	PUNCT
cblr-2960	140	8	1984	1984	NUM
cblr-2960	140	9	)	)	PUNCT
cblr-2960	140	10	(	(	PUNCT
cblr-2960	140	11	noting	note	VERB
cblr-2960	140	12	that	that	SCONJ
cblr-2960	140	13	the	the	DET
cblr-2960	140	14	diversification	diversification	NOUN
cblr-2960	140	15	requirement	requirement	NOUN
cblr-2960	140	16	was	be	AUX
cblr-2960	140	17	intended	intend	VERB
cblr-2960	140	18	to	to	PART
cblr-2960	140	19	"	"	PUNCT
cblr-2960	140	20	discourage	discourage	VERB
cblr-2960	140	21	the	the	DET
cblr-2960	140	22	use	use	NOUN
cblr-2960	140	23	of	of	ADP
cblr-2960	140	24	taxpreferred	taxpreferred	ADJ
cblr-2960	140	25	variable	variable	ADJ
cblr-2960	140	26	annuity	annuity	NOUN
cblr-2960	140	27	and	and	CCONJ
cblr-2960	140	28	variable	variable	ADJ
cblr-2960	140	29	life	life	NOUN
cblr-2960	140	30	insurance	insurance	NOUN
cblr-2960	140	31	primarily	primarily	ADV
cblr-2960	140	32	as	as	ADP
cblr-2960	140	33	investment	investment	NOUN
cblr-2960	140	34	vehicles	vehicle	NOUN
cblr-2960	140	35	"	"	PUNCT
cblr-2960	140	36	)	)	PUNCT
cblr-2960	140	37	.	.	PUNCT
cblr-2960	141	1	45	45	NUM
cblr-2960	141	2	i.r.c	i.r.c	NOUN
cblr-2960	141	3	.	.	PUNCT
cblr-2960	142	1	§	§	PROPN
cblr-2960	142	2	817(h)(1	817(h)(1	NUM
cblr-2960	142	3	)	)	PUNCT
cblr-2960	142	4	(	(	PUNCT
cblr-2960	142	5	"	"	PUNCT
cblr-2960	142	6	[	[	X
cblr-2960	142	7	a	a	X
cblr-2960	142	8	]	]	X
cblr-2960	142	9	variable	variable	ADJ
cblr-2960	142	10	contract	contract	NOUN
cblr-2960	142	11	.	.	PUNCT
cblr-2960	142	12	.	.	PUNCT
cblr-2960	142	13	.	.	PUNCT
cblr-2960	143	1	which	which	PRON
cblr-2960	143	2	is	be	AUX
cblr-2960	143	3	otherwise	otherwise	ADV
cblr-2960	143	4	described	describe	VERB
cblr-2960	143	5	in	in	ADP
cblr-2960	143	6	this	this	DET
cblr-2960	143	7	section	section	NOUN
cblr-2960	143	8	and	and	CCONJ
cblr-2960	143	9	which	which	PRON
cblr-2960	143	10	based	base	VERB
cblr-2960	143	11	on	on	ADP
cblr-2960	143	12	a	a	DET
cblr-2960	143	13	segregated	segregated	ADJ
cblr-2960	143	14	asset	asset	NOUN
cblr-2960	143	15	account	account	NOUN
cblr-2960	143	16	shall	shall	AUX
cblr-2960	143	17	not	not	PART
cblr-2960	143	18	be	be	AUX
cblr-2960	143	19	treated	treat	VERB
cblr-2960	143	20	as	as	ADP
cblr-2960	143	21	an	an	DET
cblr-2960	143	22	annuity	annuity	NOUN
cblr-2960	143	23	,	,	PUNCT
cblr-2960	143	24	endowment	endowment	NOUN
cblr-2960	143	25	,	,	PUNCT
cblr-2960	143	26	or	or	CCONJ
cblr-2960	143	27	life	life	NOUN
cblr-2960	143	28	insurance	insurance	NOUN
cblr-2960	143	29	contract	contract	NOUN
cblr-2960	143	30	for	for	ADP
cblr-2960	143	31	any	any	DET
cblr-2960	143	32	period	period	NOUN
cblr-2960	143	33	.	.	PUNCT
cblr-2960	143	34	.	.	PUNCT
cblr-2960	144	1	.	.	PUNCT
cblr-2960	145	1	for	for	ADP
cblr-2960	145	2	which	which	PRON
cblr-2960	145	3	the	the	DET
cblr-2960	145	4	investments	investment	NOUN
cblr-2960	145	5	made	make	VERB
cblr-2960	145	6	by	by	ADP
cblr-2960	145	7	such	such	ADJ
cblr-2960	145	8	account	account	NOUN
cblr-2960	145	9	are	be	AUX
cblr-2960	145	10	not	not	PART
cblr-2960	145	11	,	,	PUNCT
cblr-2960	145	12	in	in	ADP
cblr-2960	145	13	accordance	accordance	NOUN
cblr-2960	145	14	with	with	ADP
cblr-2960	145	15	regulations	regulation	NOUN
cblr-2960	145	16	prescribed	prescribe	VERB
cblr-2960	145	17	by	by	ADP
cblr-2960	145	18	the	the	DET
cblr-2960	145	19	secretary	secretary	NOUN
cblr-2960	145	20	,	,	PUNCT
cblr-2960	145	21	adequately	adequately	ADV
cblr-2960	145	22	diversified	diversified	ADJ
cblr-2960	145	23	.	.	PUNCT
cblr-2960	146	1	"	"	PUNCT
cblr-2960	146	2	)	)	PUNCT
cblr-2960	146	3	.	.	PUNCT
cblr-2960	147	1	46	46	NUM
cblr-2960	148	1	i	i	PRON
cblr-2960	148	2	d.	d.	PROPN
cblr-2960	148	3	47	47	NUM
cblr-2960	149	1	i	i	PROPN
cblr-2960	149	2	d.	d.	PROPN
cblr-2960	149	3	§	§	PROPN
cblr-2960	149	4	817(h)(4	817(h)(4	PROPN
cblr-2960	149	5	)	)	PUNCT
cblr-2960	149	6	;	;	PUNCT
cblr-2960	149	7	treas	treas	PROPN
cblr-2960	149	8	.	.	PUNCT
cblr-2960	150	1	reg	reg	PROPN
cblr-2960	150	2	.	.	PUNCT
cblr-2960	151	1	§	§	PROPN
cblr-2960	151	2	1.817	1.817	NUM
cblr-2960	151	3	-	-	SYM
cblr-2960	151	4	5(f)(2)(i	5(f)(2)(i	NUM
cblr-2960	151	5	)	)	PUNCT
cblr-2960	151	6	.	.	PUNCT
cblr-2960	152	1	4	4	NUM
cblr-2960	152	2	'	'	PART
cblr-2960	152	3	see	see	ADJ
cblr-2960	152	4	i.r.c	i.r.c	NOUN
cblr-2960	152	5	.	.	PUNCT
cblr-2960	153	1	§	§	PROPN
cblr-2960	153	2	7702(g	7702(g	NUM
cblr-2960	153	3	)	)	PUNCT
cblr-2960	153	4	.	.	PUNCT
cblr-2960	154	1	4	4	NUM
cblr-2960	154	2	'	'	PART
cblr-2960	154	3	leslie	leslie	PROPN
cblr-2960	154	4	c.	c.	PROPN
cblr-2960	154	5	giordani	giordani	PROPN
cblr-2960	154	6	,	,	PUNCT
cblr-2960	154	7	recent	recent	ADJ
cblr-2960	154	8	developments	development	NOUN
cblr-2960	154	9	affecting	affect	VERB
cblr-2960	154	10	hedge	hedge	NOUN
cblr-2960	154	11	fund	fund	NOUN
cblr-2960	154	12	investing	invest	VERB
cblr-2960	154	13	through	through	ADP
cblr-2960	154	14	private	private	ADJ
cblr-2960	154	15	placement	placement	NOUN
cblr-2960	154	16	life	life	NOUN
cblr-2960	154	17	insurance	insurance	NOUN
cblr-2960	154	18	,	,	PUNCT
cblr-2960	154	19	25	25	NUM
cblr-2960	154	20	ins	in	NOUN
cblr-2960	154	21	.	.	PUNCT
cblr-2960	155	1	tax	tax	NOUN
cblr-2960	155	2	rev	rev	PROPN
cblr-2960	155	3	.	.	PROPN
cblr-2960	155	4	579	579	NUM
cblr-2960	155	5	,	,	PUNCT
cblr-2960	155	6	579	579	NUM
cblr-2960	155	7	(	(	PUNCT
cblr-2960	155	8	2003	2003	NUM
cblr-2960	155	9	)	)	PUNCT
cblr-2960	155	10	.	.	PUNCT
cblr-2960	156	1	no	no	INTJ
cblr-2960	156	2	.	.	PUNCT
cblr-2960	157	1	2:694	2:694	NUM
cblr-2960	157	2	]	]	X
cblr-2960	157	3	columbia	columbia	PROPN
cblr-2960	157	4	business	business	PROPN
cblr-2960	157	5	law	law	PROPN
cblr-2960	157	6	review	review	VERB
cblr-2960	157	7	four	four	NUM
cblr-2960	157	8	revenue	revenue	NOUN
cblr-2960	157	9	rulings	ruling	NOUN
cblr-2960	157	10	articulating	articulate	VERB
cblr-2960	157	11	two	two	NUM
cblr-2960	157	12	guiding	guide	VERB
cblr-2960	157	13	principles	principle	NOUN
cblr-2960	157	14	:	:	PUNCT
cblr-2960	157	15	(	(	PUNCT
cblr-2960	157	16	1	1	X
cblr-2960	157	17	)	)	PUNCT
cblr-2960	157	18	the	the	DET
cblr-2960	157	19	policyholder	policyholder	NOUN
cblr-2960	157	20	may	may	AUX
cblr-2960	157	21	not	not	PART
cblr-2960	157	22	possess	possess	VERB
cblr-2960	157	23	significant	significant	ADJ
cblr-2960	157	24	control	control	NOUN
cblr-2960	157	25	or	or	CCONJ
cblr-2960	157	26	ownership	ownership	NOUN
cblr-2960	157	27	over	over	ADP
cblr-2960	157	28	the	the	DET
cblr-2960	157	29	underlying	underlie	VERB
cblr-2960	157	30	assets	asset	NOUN
cblr-2960	157	31	and	and	CCONJ
cblr-2960	157	32	(	(	PUNCT
cblr-2960	157	33	2	2	X
cblr-2960	157	34	)	)	PUNCT
cblr-2960	157	35	access	access	NOUN
cblr-2960	157	36	to	to	ADP
cblr-2960	157	37	the	the	DET
cblr-2960	157	38	investments	investment	NOUN
cblr-2960	157	39	must	must	AUX
cblr-2960	157	40	be	be	AUX
cblr-2960	157	41	exclusively	exclusively	ADV
cblr-2960	157	42	through	through	ADP
cblr-2960	157	43	the	the	DET
cblr-2960	157	44	purchase	purchase	NOUN
cblr-2960	157	45	of	of	ADP
cblr-2960	157	46	a	a	DET
cblr-2960	157	47	variable	variable	ADJ
cblr-2960	157	48	contract	contract	NOUN
cblr-2960	157	49	.	.	PUNCT
cblr-2960	158	1	"0	"0	VERB
cblr-2960	158	2	these	these	DET
cblr-2960	158	3	rulings	ruling	NOUN
cblr-2960	158	4	formed	form	VERB
cblr-2960	158	5	the	the	DET
cblr-2960	158	6	bedrock	bedrock	NOUN
cblr-2960	158	7	of	of	ADP
cblr-2960	158	8	what	what	PRON
cblr-2960	158	9	became	became	AUX
cblr-2960	158	10	known	know	VERB
cblr-2960	158	11	as	as	ADP
cblr-2960	158	12	the	the	DET
cblr-2960	158	13	investor	investor	NOUN
cblr-2960	158	14	control	control	NOUN
cblr-2960	158	15	doctrine	doctrine	NOUN
cblr-2960	158	16	.	.	PUNCT
cblr-2960	159	1	in	in	ADP
cblr-2960	159	2	1984	1984	NUM
cblr-2960	159	3	,	,	PUNCT
cblr-2960	159	4	the	the	DET
cblr-2960	159	5	united	united	PROPN
cblr-2960	159	6	states	states	PROPN
cblr-2960	159	7	court	court	PROPN
cblr-2960	159	8	of	of	ADP
cblr-2960	159	9	appeals	appeal	NOUN
cblr-2960	159	10	for	for	ADP
cblr-2960	159	11	the	the	DET
cblr-2960	159	12	eighth	eighth	ADJ
cblr-2960	159	13	circuit	circuit	NOUN
cblr-2960	159	14	adopted	adopt	VERB
cblr-2960	159	15	the	the	DET
cblr-2960	159	16	investor	investor	NOUN
cblr-2960	159	17	control	control	NOUN
cblr-2960	159	18	doctrine.51	doctrine.51	PROPN
cblr-2960	159	19	however	however	ADV
cblr-2960	159	20	,	,	PUNCT
cblr-2960	159	21	because	because	SCONJ
cblr-2960	159	22	the	the	DET
cblr-2960	159	23	diversification	diversification	NOUN
cblr-2960	159	24	requirements	requirement	NOUN
cblr-2960	159	25	of	of	ADP
cblr-2960	159	26	section	section	NOUN
cblr-2960	159	27	817	817	NUM
cblr-2960	159	28	were	be	AUX
cblr-2960	159	29	enacted	enact	VERB
cblr-2960	159	30	after	after	ADP
cblr-2960	159	31	the	the	DET
cblr-2960	159	32	rulings	ruling	NOUN
cblr-2960	159	33	that	that	PRON
cblr-2960	159	34	established	establish	VERB
cblr-2960	159	35	the	the	DET
cblr-2960	159	36	investor	investor	NOUN
cblr-2960	159	37	control	control	NOUN
cblr-2960	159	38	doctrine	doctrine	NOUN
cblr-2960	159	39	and	and	CCONJ
cblr-2960	159	40	addressed	address	VERB
cblr-2960	159	41	many	many	ADJ
cblr-2960	159	42	of	of	ADP
cblr-2960	159	43	the	the	DET
cblr-2960	159	44	same	same	ADJ
cblr-2960	159	45	issues	issue	NOUN
cblr-2960	159	46	,	,	PUNCT
cblr-2960	159	47	practitioners	practitioner	NOUN
cblr-2960	159	48	in	in	ADP
cblr-2960	159	49	the	the	DET
cblr-2960	159	50	insurance	insurance	NOUN
cblr-2960	159	51	industry	industry	NOUN
cblr-2960	159	52	assumed	assume	VERB
cblr-2960	159	53	that	that	SCONJ
cblr-2960	159	54	section	section	NOUN
cblr-2960	159	55	817	817	NUM
cblr-2960	159	56	superseded	supersede	VERB
cblr-2960	159	57	the	the	DET
cblr-2960	159	58	investor	investor	NOUN
cblr-2960	159	59	control	control	NOUN
cblr-2960	159	60	doctrine	doctrine	NOUN
cblr-2960	159	61	.	.	PUNCT
cblr-2960	160	1	nevertheless	nevertheless	ADV
cblr-2960	160	2	,	,	PUNCT
cblr-2960	160	3	the	the	DET
cblr-2960	160	4	irs	irs	PROPN
cblr-2960	160	5	has	have	AUX
cblr-2960	160	6	maintained	maintain	VERB
cblr-2960	160	7	in	in	ADP
cblr-2960	160	8	recent	recent	ADJ
cblr-2960	160	9	rulings	ruling	NOUN
cblr-2960	160	10	and	and	CCONJ
cblr-2960	160	11	reforms	reform	NOUN
cblr-2960	160	12	that	that	PRON
cblr-2960	160	13	'	'	AUX
cblr-2960	160	14	0	0	NUM
cblr-2960	160	15	see	see	VERB
cblr-2960	160	16	generally	generally	ADV
cblr-2960	160	17	rev	rev	VERB
cblr-2960	160	18	.	.	PUNCT
cblr-2960	161	1	rul	rul	NOUN
cblr-2960	161	2	.	.	PUNCT
cblr-2960	162	1	77	77	NUM
cblr-2960	162	2	-	-	SYM
cblr-2960	162	3	85	85	NUM
cblr-2960	162	4	;	;	PUNCT
cblr-2960	162	5	rev	rev	X
cblr-2960	162	6	.	.	PROPN
cblr-2960	162	7	rul	rul	PROPN
cblr-2960	162	8	.	.	PUNCT
cblr-2960	163	1	80	80	NUM
cblr-2960	163	2	-	-	SYM
cblr-2960	163	3	274	274	NUM
cblr-2960	163	4	;	;	PUNCT
cblr-2960	163	5	rev	rev	X
cblr-2960	163	6	.	.	PROPN
cblr-2960	164	1	rul	rul	PROPN
cblr-2960	164	2	.	.	PUNCT
cblr-2960	165	1	81	81	NUM
cblr-2960	165	2	-	-	SYM
cblr-2960	165	3	225	225	NUM
cblr-2960	165	4	;	;	PUNCT
cblr-2960	165	5	rev	rev	X
cblr-2960	165	6	.	.	PROPN
cblr-2960	166	1	rul	rul	PROPN
cblr-2960	166	2	.	.	PUNCT
cblr-2960	166	3	82	82	NUM
cblr-2960	166	4	-	-	SYM
cblr-2960	166	5	54	54	NUM
cblr-2960	166	6	(	(	PUNCT
cblr-2960	166	7	expressing	express	VERB
cblr-2960	166	8	the	the	DET
cblr-2960	166	9	principles	principle	NOUN
cblr-2960	166	10	that	that	SCONJ
cblr-2960	166	11	(	(	PUNCT
cblr-2960	166	12	1	1	X
cblr-2960	166	13	)	)	PUNCT
cblr-2960	166	14	if	if	SCONJ
cblr-2960	166	15	the	the	DET
cblr-2960	166	16	investor	investor	NOUN
cblr-2960	166	17	possesses	possess	VERB
cblr-2960	166	18	significant	significant	ADJ
cblr-2960	166	19	incidents	incident	NOUN
cblr-2960	166	20	control	control	NOUN
cblr-2960	166	21	and	and	CCONJ
cblr-2960	166	22	ownership	ownership	NOUN
cblr-2960	166	23	over	over	ADP
cblr-2960	166	24	the	the	DET
cblr-2960	166	25	asset	asset	NOUN
cblr-2960	166	26	,	,	PUNCT
cblr-2960	166	27	the	the	DET
cblr-2960	166	28	person	person	NOUN
cblr-2960	166	29	is	be	AUX
cblr-2960	166	30	treated	treat	VERB
cblr-2960	166	31	as	as	ADP
cblr-2960	166	32	the	the	DET
cblr-2960	166	33	owner	owner	NOUN
cblr-2960	166	34	of	of	ADP
cblr-2960	166	35	an	an	DET
cblr-2960	166	36	asset	asset	NOUN
cblr-2960	166	37	,	,	PUNCT
cblr-2960	166	38	regardless	regardless	ADV
cblr-2960	166	39	of	of	ADP
cblr-2960	166	40	who	who	PRON
cblr-2960	166	41	holds	hold	VERB
cblr-2960	166	42	legal	legal	ADJ
cblr-2960	166	43	title	title	NOUN
cblr-2960	166	44	to	to	ADP
cblr-2960	166	45	it	it	PRON
cblr-2960	166	46	and	and	CCONJ
cblr-2960	166	47	(	(	PUNCT
cblr-2960	166	48	2	2	X
cblr-2960	166	49	)	)	PUNCT
cblr-2960	166	50	an	an	DET
cblr-2960	166	51	investor	investor	NOUN
cblr-2960	166	52	may	may	AUX
cblr-2960	166	53	not	not	PART
cblr-2960	166	54	invest	invest	VERB
cblr-2960	166	55	in	in	ADP
cblr-2960	166	56	a	a	DET
cblr-2960	166	57	fund	fund	NOUN
cblr-2960	166	58	that	that	PRON
cblr-2960	166	59	is	be	AUX
cblr-2960	166	60	also	also	ADV
cblr-2960	166	61	available	available	ADJ
cblr-2960	166	62	for	for	ADP
cblr-2960	166	63	investment	investment	NOUN
cblr-2960	166	64	by	by	ADP
cblr-2960	166	65	the	the	DET
cblr-2960	166	66	general	general	ADJ
cblr-2960	166	67	public	public	NOUN
cblr-2960	166	68	)	)	PUNCT
cblr-2960	166	69	.	.	PUNCT
cblr-2960	167	1	if	if	SCONJ
cblr-2960	167	2	the	the	DET
cblr-2960	167	3	investor	investor	NOUN
cblr-2960	167	4	maintains	maintain	VERB
cblr-2960	167	5	a	a	DET
cblr-2960	167	6	prohibited	prohibit	VERB
cblr-2960	167	7	interest	interest	NOUN
cblr-2960	167	8	under	under	ADP
cblr-2960	167	9	the	the	DET
cblr-2960	167	10	investor	investor	NOUN
cblr-2960	167	11	control	control	NOUN
cblr-2960	167	12	doctrine	doctrine	NOUN
cblr-2960	167	13	,	,	PUNCT
cblr-2960	167	14	the	the	DET
cblr-2960	167	15	contract	contract	NOUN
cblr-2960	167	16	holder	holder	NOUN
cblr-2960	167	17	must	must	AUX
cblr-2960	167	18	then	then	ADV
cblr-2960	167	19	include	include	VERB
cblr-2960	167	20	any	any	DET
cblr-2960	167	21	interest	interest	NOUN
cblr-2960	167	22	,	,	PUNCT
cblr-2960	167	23	dividends	dividend	NOUN
cblr-2960	167	24	,	,	PUNCT
cblr-2960	167	25	or	or	CCONJ
cblr-2960	167	26	other	other	ADJ
cblr-2960	167	27	income	income	NOUN
cblr-2960	167	28	derived	derive	VERB
cblr-2960	167	29	from	from	ADP
cblr-2960	167	30	the	the	DET
cblr-2960	167	31	partnership	partnership	NOUN
cblr-2960	167	32	interests	interest	NOUN
cblr-2960	167	33	in	in	ADP
cblr-2960	167	34	his	his	PRON
cblr-2960	167	35	or	or	CCONJ
cblr-2960	167	36	her	her	PRON
cblr-2960	167	37	gross	gross	ADJ
cblr-2960	167	38	income	income	NOUN
cblr-2960	167	39	.	.	PUNCT
cblr-2960	167	40	i.r.c	i.r.c	NOUN
cblr-2960	167	41	.	.	PUNCT
cblr-2960	168	1	§	§	PROPN
cblr-2960	168	2	61(a	61(a	NUM
cblr-2960	168	3	)	)	PUNCT
cblr-2960	168	4	.	.	PUNCT
cblr-2960	168	5	"	"	PUNCT
cblr-2960	169	1	christofferson	christofferson	PROPN
cblr-2960	169	2	v.	v.	PROPN
cblr-2960	169	3	united	united	PROPN
cblr-2960	169	4	states	states	PROPN
cblr-2960	169	5	,	,	PUNCT
cblr-2960	169	6	749	749	NUM
cblr-2960	169	7	f.2d	f.2d	SYM
cblr-2960	169	8	513	513	NUM
cblr-2960	169	9	(	(	PUNCT
cblr-2960	169	10	8th	8th	ADJ
cblr-2960	169	11	cir	cir	NOUN
cblr-2960	169	12	.	.	PUNCT
cblr-2960	169	13	1984	1984	NUM
cblr-2960	169	14	)	)	PUNCT
cblr-2960	169	15	.	.	PUNCT
cblr-2960	170	1	in	in	ADP
cblr-2960	170	2	chistofferson	chistofferson	PROPN
cblr-2960	170	3	,	,	PUNCT
cblr-2960	170	4	the	the	DET
cblr-2960	170	5	taxpayer	taxpayer	NOUN
cblr-2960	170	6	purchased	purchase	VERB
cblr-2960	170	7	a	a	DET
cblr-2960	170	8	variable	variable	ADJ
cblr-2960	170	9	annuity	annuity	NOUN
cblr-2960	170	10	contract	contract	NOUN
cblr-2960	170	11	in	in	ADP
cblr-2960	170	12	which	which	PRON
cblr-2960	170	13	he	he	PRON
cblr-2960	170	14	had	have	VERB
cblr-2960	170	15	the	the	DET
cblr-2960	170	16	power	power	NOUN
cblr-2960	170	17	to	to	PART
cblr-2960	170	18	direct	direct	VERB
cblr-2960	170	19	the	the	DET
cblr-2960	170	20	investment	investment	NOUN
cblr-2960	170	21	of	of	ADP
cblr-2960	170	22	premiums	premium	NOUN
cblr-2960	170	23	,	,	PUNCT
cblr-2960	170	24	to	to	PART
cblr-2960	170	25	reallocate	reallocate	VERB
cblr-2960	170	26	their	their	PRON
cblr-2960	170	27	investment	investment	NOUN
cblr-2960	170	28	among	among	ADP
cblr-2960	170	29	the	the	DET
cblr-2960	170	30	funds	fund	NOUN
cblr-2960	170	31	at	at	ADP
cblr-2960	170	32	any	any	DET
cblr-2960	170	33	time	time	NOUN
cblr-2960	170	34	,	,	PUNCT
cblr-2960	170	35	to	to	PART
cblr-2960	170	36	make	make	VERB
cblr-2960	170	37	withdrawals	withdrawal	NOUN
cblr-2960	170	38	,	,	PUNCT
cblr-2960	170	39	to	to	PART
cblr-2960	170	40	surrender	surrender	VERB
cblr-2960	170	41	the	the	DET
cblr-2960	170	42	contract	contract	NOUN
cblr-2960	170	43	,	,	PUNCT
cblr-2960	170	44	and	and	CCONJ
cblr-2960	170	45	to	to	PART
cblr-2960	170	46	apply	apply	VERB
cblr-2960	170	47	the	the	DET
cblr-2960	170	48	contract	contract	NOUN
cblr-2960	170	49	's	's	PART
cblr-2960	170	50	accumulated	accumulate	VERB
cblr-2960	170	51	value	value	NOUN
cblr-2960	170	52	to	to	PART
cblr-2960	170	53	provide	provide	VERB
cblr-2960	170	54	annuity	annuity	NOUN
cblr-2960	170	55	payments	payment	NOUN
cblr-2960	170	56	.	.	PUNCT
cblr-2960	171	1	i	i	PRON
cblr-2960	171	2	d.	d.	PROPN
cblr-2960	171	3	the	the	DET
cblr-2960	171	4	court	court	NOUN
cblr-2960	171	5	held	hold	VERB
cblr-2960	171	6	that	that	SCONJ
cblr-2960	171	7	because	because	SCONJ
cblr-2960	171	8	the	the	DET
cblr-2960	171	9	taxpayers	taxpayer	NOUN
cblr-2960	171	10	had	have	AUX
cblr-2960	171	11	surrendered	surrender	VERB
cblr-2960	171	12	few	few	ADJ
cblr-2960	171	13	of	of	ADP
cblr-2960	171	14	the	the	DET
cblr-2960	171	15	rights	right	NOUN
cblr-2960	171	16	of	of	ADP
cblr-2960	171	17	ownership	ownership	NOUN
cblr-2960	171	18	or	or	CCONJ
cblr-2960	171	19	control	control	NOUN
cblr-2960	171	20	over	over	ADP
cblr-2960	171	21	the	the	DET
cblr-2960	171	22	assets	asset	NOUN
cblr-2960	171	23	of	of	ADP
cblr-2960	171	24	the	the	DET
cblr-2960	171	25	separate	separate	ADJ
cblr-2960	171	26	account	account	NOUN
cblr-2960	171	27	,	,	PUNCT
cblr-2960	171	28	it	it	PRON
cblr-2960	171	29	must	must	AUX
cblr-2960	171	30	conclude	conclude	VERB
cblr-2960	171	31	that	that	SCONJ
cblr-2960	171	32	the	the	DET
cblr-2960	171	33	taxpayers	taxpayer	NOUN
cblr-2960	171	34	,	,	PUNCT
cblr-2960	171	35	and	and	CCONJ
cblr-2960	171	36	not	not	PART
cblr-2960	171	37	the	the	DET
cblr-2960	171	38	insurance	insurance	NOUN
cblr-2960	171	39	company	company	NOUN
cblr-2960	171	40	,	,	PUNCT
cblr-2960	171	41	effectively	effectively	ADV
cblr-2960	171	42	owned	own	VERB
cblr-2960	171	43	the	the	DET
cblr-2960	171	44	separate	separate	ADJ
cblr-2960	171	45	account	account	NOUN
cblr-2960	171	46	assets	asset	NOUN
cblr-2960	171	47	.	.	PUNCT
cblr-2960	172	1	i	i	PRON
cblr-2960	172	2	d.	d.	PROPN
cblr-2960	172	3	5	5	NUM
cblr-2960	172	4	see	see	VERB
cblr-2960	172	5	giordani	giordani	NOUN
cblr-2960	172	6	,	,	PUNCT
cblr-2960	172	7	supra	supra	PROPN
cblr-2960	172	8	note	note	NOUN
cblr-2960	172	9	49	49	NUM
cblr-2960	172	10	,	,	PUNCT
cblr-2960	172	11	at	at	ADP
cblr-2960	172	12	579	579	NUM
cblr-2960	172	13	(	(	PUNCT
cblr-2960	172	14	arguing	argue	VERB
cblr-2960	172	15	that	that	SCONJ
cblr-2960	172	16	"	"	PUNCT
cblr-2960	172	17	if	if	SCONJ
cblr-2960	172	18	the	the	DET
cblr-2960	172	19	investor	investor	NOUN
cblr-2960	172	20	control	control	NOUN
cblr-2960	172	21	doctrine	doctrine	NOUN
cblr-2960	172	22	still	still	ADV
cblr-2960	172	23	applies	apply	VERB
cblr-2960	172	24	to	to	PART
cblr-2960	172	25	cause	cause	VERB
cblr-2960	172	26	the	the	DET
cblr-2960	172	27	assets	asset	NOUN
cblr-2960	172	28	of	of	ADP
cblr-2960	172	29	the	the	DET
cblr-2960	172	30	segregated	segregated	ADJ
cblr-2960	172	31	account	account	NOUN
cblr-2960	172	32	to	to	PART
cblr-2960	172	33	be	be	AUX
cblr-2960	172	34	owned	own	VERB
cblr-2960	172	35	by	by	ADP
cblr-2960	172	36	the	the	DET
cblr-2960	172	37	policy	policy	NOUN
cblr-2960	172	38	owner	owner	NOUN
cblr-2960	172	39	for	for	ADP
cblr-2960	172	40	federal	federal	ADJ
cblr-2960	172	41	income	income	NOUN
cblr-2960	172	42	tax	tax	NOUN
cblr-2960	172	43	purposes	purpose	NOUN
cblr-2960	172	44	if	if	SCONJ
cblr-2960	172	45	investment	investment	NOUN
cblr-2960	172	46	in	in	ADP
cblr-2960	172	47	the	the	DET
cblr-2960	172	48	partnership	partnership	NOUN
cblr-2960	172	49	is	be	AUX
cblr-2960	172	50	available	available	ADJ
cblr-2960	172	51	to	to	ADP
cblr-2960	172	52	public	public	ADJ
cblr-2960	172	53	investors	investor	NOUN
cblr-2960	172	54	,	,	PUNCT
cblr-2960	172	55	then	then	ADV
cblr-2960	172	56	there	there	PRON
cblr-2960	172	57	was	be	VERB
cblr-2960	172	58	no	no	DET
cblr-2960	172	59	point	point	NOUN
cblr-2960	172	60	in	in	ADP
cblr-2960	172	61	applying	apply	VERB
cblr-2960	172	62	look	look	NOUN
cblr-2960	172	63	-	-	PUNCT
cblr-2960	172	64	through	through	NOUN
cblr-2960	172	65	to	to	PART
cblr-2960	172	66	determine	determine	VERB
cblr-2960	172	67	diversification	diversification	NOUN
cblr-2960	172	68	in	in	ADP
cblr-2960	172	69	the	the	DET
cblr-2960	172	70	first	first	ADJ
cblr-2960	172	71	place	place	NOUN
cblr-2960	172	72	"	"	PUNCT
cblr-2960	172	73	)	)	PUNCT
cblr-2960	172	74	;	;	PUNCT
cblr-2960	172	75	see	see	VERB
cblr-2960	172	76	also	also	ADV
cblr-2960	172	77	david	david	PROPN
cblr-2960	172	78	s.	s.	PROPN
cblr-2960	172	79	neufeld	neufeld	PROPN
cblr-2960	172	80	,	,	PUNCT
cblr-2960	172	81	the	the	DET
cblr-2960	172	82	keyport	keyport	PROPN
cblr-2960	172	83	ruling	ruling	NOUN
cblr-2960	172	84	and	and	CCONJ
cblr-2960	172	85	the	the	DET
cblr-2960	172	86	investor	investor	NOUN
cblr-2960	172	87	control	control	NOUN
cblr-2960	172	88	rule	rule	NOUN
cblr-2960	172	89	:	:	PUNCT
cblr-2960	172	90	might	might	AUX
cblr-2960	172	91	makes	make	VERB
cblr-2960	172	92	right	right	ADJ
cblr-2960	172	93	?	?	PUNCT
cblr-2960	172	94	,	,	PUNCT
cblr-2960	172	95	98	98	NUM
cblr-2960	172	96	tax	tax	NOUN
cblr-2960	172	97	notes	note	NOUN
cblr-2960	172	98	403	403	NUM
cblr-2960	172	99	,	,	PUNCT
cblr-2960	172	100	405	405	NUM
cblr-2960	172	101	(	(	PUNCT
cblr-2960	172	102	2003	2003	NUM
cblr-2960	172	103	)	)	PUNCT
cblr-2960	172	104	(	(	PUNCT
cblr-2960	172	105	arguing	argue	VERB
cblr-2960	172	106	that	that	SCONJ
cblr-2960	172	107	the	the	DET
cblr-2960	172	108	approach	approach	NOUN
cblr-2960	172	109	of	of	ADP
cblr-2960	172	110	applying	apply	VERB
cblr-2960	172	111	both	both	CCONJ
cblr-2960	172	112	the	the	DET
cblr-2960	172	113	investor	investor	NOUN
cblr-2960	172	114	control	control	NOUN
cblr-2960	172	115	doctrine	doctrine	NOUN
cblr-2960	172	116	and	and	CCONJ
cblr-2960	172	117	diversification	diversification	NOUN
cblr-2960	172	118	test	test	NOUN
cblr-2960	172	119	is	be	AUX
cblr-2960	172	120	"	"	PUNCT
cblr-2960	172	121	implicitly	implicitly	ADV
cblr-2960	172	122	unworkable	unworkable	ADJ
cblr-2960	172	123	,	,	PUNCT
cblr-2960	172	124	confused	confused	ADJ
cblr-2960	172	125	,	,	PUNCT
cblr-2960	172	126	and	and	CCONJ
cblr-2960	172	127	confusing	confusing	ADJ
cblr-2960	172	128	"	"	PUNCT
cblr-2960	172	129	)	)	PUNCT
cblr-2960	172	130	.	.	PUNCT
cblr-2960	173	1	[	[	X
cblr-2960	173	2	vol	vol	NOUN
cblr-2960	173	3	.	.	NOUN
cblr-2960	173	4	2008	2008	NUM
cblr-2960	173	5	job	job	NOUN
cblr-2960	173	6	well	well	ADV
cblr-2960	173	7	done	do	VERB
cblr-2960	173	8	the	the	DET
cblr-2960	173	9	investor	investor	NOUN
cblr-2960	173	10	control	control	NOUN
cblr-2960	173	11	doctrine	doctrine	NOUN
cblr-2960	173	12	remains	remain	VERB
cblr-2960	173	13	an	an	DET
cblr-2960	173	14	independent	independent	ADJ
cblr-2960	173	15	theoretical	theoretical	ADJ
cblr-2960	173	16	basis	basis	NOUN
cblr-2960	173	17	for	for	ADP
cblr-2960	173	18	denying	deny	VERB
cblr-2960	173	19	deferral	deferral	ADV
cblr-2960	173	20	on	on	ADP
cblr-2960	173	21	gains	gain	NOUN
cblr-2960	173	22	earned	earn	VERB
cblr-2960	173	23	within	within	ADP
cblr-2960	173	24	variable	variable	ADJ
cblr-2960	173	25	life	life	NOUN
cblr-2960	173	26	insurance	insurance	NOUN
cblr-2960	173	27	policies	policy	NOUN
cblr-2960	173	28	.	.	PUNCT
cblr-2960	174	1	3	3	NUM
cblr-2960	174	2	1	1	NUM
cblr-2960	174	3	.	.	PUNCT
cblr-2960	175	1	the	the	DET
cblr-2960	175	2	first	first	ADJ
cblr-2960	175	3	prong	prong	NOUN
cblr-2960	175	4	-	-	PUNCT
cblr-2960	175	5	control	control	NOUN
cblr-2960	175	6	by	by	ADP
cblr-2960	175	7	the	the	DET
cblr-2960	175	8	investor	investor	NOUN
cblr-2960	175	9	revenue	revenue	NOUN
cblr-2960	175	10	ruling	ruling	NOUN
cblr-2960	175	11	2003	2003	NUM
cblr-2960	175	12	-	-	SYM
cblr-2960	175	13	91	91	NUM
cblr-2960	175	14	reaffirms	reaffirm	VERB
cblr-2960	175	15	the	the	DET
cblr-2960	175	16	first	first	ADJ
cblr-2960	175	17	prong	prong	NOUN
cblr-2960	175	18	of	of	ADP
cblr-2960	175	19	the	the	DET
cblr-2960	175	20	investor	investor	NOUN
cblr-2960	175	21	control	control	NOUN
cblr-2960	175	22	doctrine	doctrine	NOUN
cblr-2960	175	23	,	,	PUNCT
cblr-2960	175	24	holding	hold	VERB
cblr-2960	175	25	that	that	SCONJ
cblr-2960	175	26	even	even	ADV
cblr-2960	175	27	if	if	SCONJ
cblr-2960	175	28	a	a	DET
cblr-2960	175	29	wrapped	wrap	VERB
cblr-2960	175	30	investment	investment	NOUN
cblr-2960	175	31	satisfies	satisfy	VERB
cblr-2960	175	32	the	the	DET
cblr-2960	175	33	diversification	diversification	NOUN
cblr-2960	175	34	requirements	requirement	NOUN
cblr-2960	175	35	of	of	ADP
cblr-2960	175	36	section	section	NOUN
cblr-2960	175	37	817(h	817(h	PROPN
cblr-2960	175	38	)	)	PUNCT
cblr-2960	175	39	,	,	PUNCT
cblr-2960	175	40	the	the	DET
cblr-2960	175	41	irs	irs	PROPN
cblr-2960	175	42	may	may	AUX
cblr-2960	175	43	still	still	ADV
cblr-2960	175	44	disregard	disregard	VERB
cblr-2960	175	45	the	the	DET
cblr-2960	175	46	form	form	NOUN
cblr-2960	175	47	of	of	ADP
cblr-2960	175	48	the	the	DET
cblr-2960	175	49	transaction	transaction	NOUN
cblr-2960	175	50	when	when	SCONJ
cblr-2960	175	51	the	the	DET
cblr-2960	175	52	policyholder	policyholder	NOUN
cblr-2960	175	53	retains	retain	VERB
cblr-2960	175	54	dominion	dominion	NOUN
cblr-2960	175	55	and	and	CCONJ
cblr-2960	175	56	control	control	NOUN
cblr-2960	175	57	over	over	ADP
cblr-2960	175	58	the	the	DET
cblr-2960	175	59	investments	investment	NOUN
cblr-2960	175	60	held	hold	VERB
cblr-2960	175	61	within	within	ADP
cblr-2960	175	62	the	the	DET
cblr-2960	175	63	policy	policy	NOUN
cblr-2960	175	64	.	.	PUNCT
cblr-2960	176	1	4	4	NUM
cblr-2960	176	2	the	the	DET
cblr-2960	176	3	irs	irs	PROPN
cblr-2960	176	4	has	have	AUX
cblr-2960	176	5	made	make	VERB
cblr-2960	176	6	it	it	PRON
cblr-2960	176	7	clear	clear	ADJ
cblr-2960	176	8	that	that	SCONJ
cblr-2960	176	9	all	all	DET
cblr-2960	176	10	investment	investment	NOUN
cblr-2960	176	11	decisions	decision	NOUN
cblr-2960	176	12	must	must	AUX
cblr-2960	176	13	be	be	AUX
cblr-2960	176	14	made	make	VERB
cblr-2960	176	15	by	by	ADP
cblr-2960	176	16	the	the	DET
cblr-2960	176	17	insurance	insurance	NOUN
cblr-2960	176	18	company	company	NOUN
cblr-2960	176	19	or	or	CCONJ
cblr-2960	176	20	its	its	PRON
cblr-2960	176	21	investment	investment	NOUN
cblr-2960	176	22	advisor	advisor	NOUN
cblr-2960	176	23	in	in	ADP
cblr-2960	176	24	their	their	PRON
cblr-2960	176	25	sole	sole	ADJ
cblr-2960	176	26	and	and	CCONJ
cblr-2960	176	27	absolute	absolute	ADJ
cblr-2960	176	28	discretion	discretion	NOUN
cblr-2960	176	29	,	,	PUNCT
cblr-2960	176	30	without	without	ADP
cblr-2960	176	31	arrangement	arrangement	NOUN
cblr-2960	176	32	or	or	CCONJ
cblr-2960	176	33	agreement	agreement	NOUN
cblr-2960	176	34	between	between	ADP
cblr-2960	176	35	the	the	DET
cblr-2960	176	36	policyholder	policyholder	NOUN
cblr-2960	176	37	and	and	CCONJ
cblr-2960	176	38	the	the	DET
cblr-2960	176	39	insurance	insurance	NOUN
cblr-2960	176	40	company	company	NOUN
cblr-2960	176	41	regarding	regard	VERB
cblr-2960	176	42	the	the	DET
cblr-2960	176	43	specific	specific	ADJ
cblr-2960	176	44	investments	investment	NOUN
cblr-2960	176	45	or	or	CCONJ
cblr-2960	176	46	investment	investment	NOUN
cblr-2960	176	47	objectives	objective	NOUN
cblr-2960	176	48	of	of	ADP
cblr-2960	176	49	a	a	DET
cblr-2960	176	50	specific	specific	ADJ
cblr-2960	176	51	investment	investment	NOUN
cblr-2960	176	52	vehicle.55	vehicle.55	NOUN
cblr-2960	176	53	the	the	DET
cblr-2960	176	54	service	service	NOUN
cblr-2960	176	55	has	have	AUX
cblr-2960	176	56	explained	explain	VERB
cblr-2960	176	57	that	that	SCONJ
cblr-2960	176	58	the	the	DET
cblr-2960	176	59	policyholder	policyholder	NOUN
cblr-2960	176	60	can	can	AUX
cblr-2960	176	61	not	not	PART
cblr-2960	176	62	select	select	VERB
cblr-2960	176	63	,	,	PUNCT
cblr-2960	176	64	manage	manage	VERB
cblr-2960	176	65	,	,	PUNCT
cblr-2960	176	66	or	or	CCONJ
cblr-2960	176	67	control	control	VERB
cblr-2960	176	68	the	the	DET
cblr-2960	176	69	investments	investment	NOUN
cblr-2960	176	70	of	of	ADP
cblr-2960	176	71	the	the	DET
cblr-2960	176	72	segregated	segregated	ADJ
cblr-2960	176	73	account	account	NOUN
cblr-2960	176	74	.	.	PUNCT
cblr-2960	177	1	6	6	NUM
cblr-2960	177	2	"	"	PUNCT
cblr-2960	177	3	andrew	andrew	PROPN
cblr-2960	177	4	w.	w.	PROPN
cblr-2960	177	5	needham	needham	PROPN
cblr-2960	177	6	&	&	CCONJ
cblr-2960	177	7	christian	christian	PROPN
cblr-2960	177	8	brause	brause	NOUN
cblr-2960	177	9	,	,	PUNCT
cblr-2960	177	10	736	736	NUM
cblr-2960	177	11	t.m	t.m	PROPN
cblr-2960	177	12	.	.	PROPN
cblr-2960	177	13	,	,	PUNCT
cblr-2960	177	14	hedge	hedge	NOUN
cblr-2960	177	15	funds	fund	NOUN
cblr-2960	177	16	,	,	PUNCT
cblr-2960	177	17	at	at	ADP
cblr-2960	177	18	a-101	a-101	PROPN
cblr-2960	177	19	(	(	PUNCT
cblr-2960	177	20	"	"	PUNCT
cblr-2960	177	21	for	for	ADP
cblr-2960	177	22	example	example	NOUN
cblr-2960	177	23	,	,	PUNCT
cblr-2960	177	24	if	if	SCONJ
cblr-2960	177	25	the	the	DET
cblr-2960	177	26	policyholder	policyholder	NOUN
cblr-2960	177	27	retains	retain	VERB
cblr-2960	177	28	the	the	DET
cblr-2960	177	29	right	right	NOUN
cblr-2960	177	30	to	to	PART
cblr-2960	177	31	vote	vote	VERB
cblr-2960	177	32	,	,	PUNCT
cblr-2960	177	33	to	to	ADP
cblr-2960	177	34	direct	direct	ADJ
cblr-2960	177	35	investment	investment	NOUN
cblr-2960	177	36	,	,	PUNCT
cblr-2960	177	37	or	or	CCONJ
cblr-2960	177	38	to	to	PART
cblr-2960	177	39	otherwise	otherwise	ADV
cblr-2960	177	40	act	act	VERB
cblr-2960	177	41	on	on	ADP
cblr-2960	177	42	behalf	behalf	NOUN
cblr-2960	177	43	of	of	ADP
cblr-2960	177	44	the	the	DET
cblr-2960	177	45	insurance	insurance	NOUN
cblr-2960	177	46	company	company	NOUN
cblr-2960	177	47	investors	investor	NOUN
cblr-2960	177	48	in	in	ADP
cblr-2960	177	49	the	the	DET
cblr-2960	177	50	fund	fund	NOUN
cblr-2960	177	51	,	,	PUNCT
cblr-2960	177	52	the	the	DET
cblr-2960	177	53	irs	irs	PROPN
cblr-2960	177	54	may	may	AUX
cblr-2960	177	55	assert	assert	VERB
cblr-2960	177	56	that	that	SCONJ
cblr-2960	177	57	the	the	DET
cblr-2960	177	58	insurance	insurance	NOUN
cblr-2960	177	59	company	company	NOUN
cblr-2960	177	60	is	be	AUX
cblr-2960	177	61	acting	act	VERB
cblr-2960	177	62	as	as	ADP
cblr-2960	177	63	an	an	DET
cblr-2960	177	64	agent	agent	NOUN
cblr-2960	177	65	of	of	ADP
cblr-2960	177	66	the	the	DET
cblr-2960	177	67	policyholder	policyholder	NOUN
cblr-2960	177	68	.	.	PUNCT
cblr-2960	177	69	"	"	PUNCT
cblr-2960	177	70	)	)	PUNCT
cblr-2960	177	71	;	;	PUNCT
cblr-2960	177	72	see	see	VERB
cblr-2960	177	73	also	also	ADV
cblr-2960	177	74	neufeld	neufeld	PROPN
cblr-2960	177	75	,	,	PUNCT
cblr-2960	177	76	supra	supra	PROPN
cblr-2960	177	77	note	note	NOUN
cblr-2960	177	78	52	52	NUM
cblr-2960	177	79	,	,	PUNCT
cblr-2960	177	80	at	at	ADP
cblr-2960	177	81	404	404	NUM
cblr-2960	177	82	(	(	PUNCT
cblr-2960	177	83	explaining	explain	VERB
cblr-2960	177	84	that	that	SCONJ
cblr-2960	177	85	the	the	DET
cblr-2960	177	86	investor	investor	NOUN
cblr-2960	177	87	control	control	NOUN
cblr-2960	177	88	doctrine	doctrine	NOUN
cblr-2960	177	89	is	be	AUX
cblr-2960	177	90	violated	violate	VERB
cblr-2960	177	91	when	when	SCONJ
cblr-2960	177	92	either	either	CCONJ
cblr-2960	177	93	(	(	PUNCT
cblr-2960	177	94	1	1	X
cblr-2960	177	95	)	)	PUNCT
cblr-2960	177	96	an	an	DET
cblr-2960	177	97	insurance	insurance	NOUN
cblr-2960	177	98	policy	policy	NOUN
cblr-2960	177	99	owner	owner	NOUN
cblr-2960	177	100	possesses	possess	VERB
cblr-2960	177	101	too	too	ADV
cblr-2960	177	102	many	many	ADJ
cblr-2960	177	103	rights	right	NOUN
cblr-2960	177	104	to	to	PART
cblr-2960	177	105	control	control	VERB
cblr-2960	177	106	the	the	DET
cblr-2960	177	107	actual	actual	ADJ
cblr-2960	177	108	investments	investment	NOUN
cblr-2960	177	109	held	hold	VERB
cblr-2960	177	110	within	within	ADP
cblr-2960	177	111	the	the	DET
cblr-2960	177	112	variable	variable	ADJ
cblr-2960	177	113	contract	contract	NOUN
cblr-2960	177	114	,	,	PUNCT
cblr-2960	177	115	or	or	CCONJ
cblr-2960	177	116	(	(	PUNCT
cblr-2960	177	117	2	2	X
cblr-2960	177	118	)	)	PUNCT
cblr-2960	177	119	the	the	DET
cblr-2960	177	120	segregated	segregated	ADJ
cblr-2960	177	121	account	account	NOUN
cblr-2960	177	122	of	of	ADP
cblr-2960	177	123	the	the	DET
cblr-2960	177	124	variable	variable	ADJ
cblr-2960	177	125	contract	contract	NOUN
cblr-2960	177	126	is	be	AUX
cblr-2960	177	127	invested	invest	VERB
cblr-2960	177	128	in	in	ADP
cblr-2960	177	129	funds	fund	NOUN
cblr-2960	177	130	in	in	ADP
cblr-2960	177	131	which	which	PRON
cblr-2960	177	132	the	the	DET
cblr-2960	177	133	general	general	ADJ
cblr-2960	177	134	public	public	NOUN
cblr-2960	177	135	may	may	AUX
cblr-2960	177	136	also	also	ADV
cblr-2960	177	137	invest	invest	VERB
cblr-2960	177	138	)	)	PUNCT
cblr-2960	177	139	.	.	PUNCT
cblr-2960	178	1	14	14	NUM
cblr-2960	178	2	see	see	VERB
cblr-2960	178	3	needham	needham	PROPN
cblr-2960	178	4	&	&	CCONJ
cblr-2960	178	5	brause	brause	PROPN
cblr-2960	178	6	,	,	PUNCT
cblr-2960	178	7	supra	supra	PROPN
cblr-2960	178	8	note	note	NOUN
cblr-2960	178	9	53	53	NUM
cblr-2960	178	10	(	(	PUNCT
cblr-2960	178	11	stating	state	VERB
cblr-2960	178	12	that	that	SCONJ
cblr-2960	178	13	if	if	SCONJ
cblr-2960	178	14	the	the	DET
cblr-2960	178	15	investor	investor	NOUN
cblr-2960	178	16	asserts	assert	VERB
cblr-2960	178	17	control	control	NOUN
cblr-2960	178	18	over	over	ADP
cblr-2960	178	19	the	the	DET
cblr-2960	178	20	underlying	underlie	VERB
cblr-2960	178	21	investments	investment	NOUN
cblr-2960	178	22	,	,	PUNCT
cblr-2960	178	23	the	the	DET
cblr-2960	178	24	irs	irs	PROPN
cblr-2960	178	25	will	will	AUX
cblr-2960	178	26	treat	treat	VERB
cblr-2960	178	27	the	the	DET
cblr-2960	178	28	policyholder	policyholder	NOUN
cblr-2960	178	29	as	as	ADP
cblr-2960	178	30	the	the	DET
cblr-2960	178	31	owner	owner	NOUN
cblr-2960	178	32	of	of	ADP
cblr-2960	178	33	the	the	DET
cblr-2960	178	34	wrapped	wrap	VERB
cblr-2960	178	35	investment	investment	NOUN
cblr-2960	178	36	without	without	ADP
cblr-2960	178	37	regard	regard	NOUN
cblr-2960	178	38	to	to	ADP
cblr-2960	178	39	whether	whether	SCONJ
cblr-2960	178	40	the	the	DET
cblr-2960	178	41	contract	contract	NOUN
cblr-2960	178	42	satisfies	satisfy	VERB
cblr-2960	178	43	the	the	DET
cblr-2960	178	44	section	section	NOUN
cblr-2960	178	45	817(h	817(h	PROPN
cblr-2960	178	46	)	)	PUNCT
cblr-2960	178	47	diversification	diversification	NOUN
cblr-2960	178	48	requirements	requirement	NOUN
cblr-2960	178	49	)	)	PUNCT
cblr-2960	178	50	.	.	PUNCT
cblr-2960	178	51	"	"	PUNCT
cblr-2960	179	1	david	david	PROPN
cblr-2960	179	2	s.	s.	PROPN
cblr-2960	179	3	neufeld	neufeld	PROPN
cblr-2960	179	4	,	,	PUNCT
cblr-2960	179	5	to	to	ADP
cblr-2960	179	6	idf	idf	PROPN
cblr-2960	179	7	or	or	CCONJ
cblr-2960	179	8	not	not	PART
cblr-2960	179	9	to	to	ADP
cblr-2960	179	10	idf	idf	PROPN
cblr-2960	179	11	:	:	PUNCT
cblr-2960	179	12	can	can	AUX
cblr-2960	179	13	insurance	insurance	NOUN
cblr-2960	179	14	companies	company	NOUN
cblr-2960	179	15	allocate	allocate	VERB
cblr-2960	179	16	to	to	ADP
cblr-2960	179	17	public	public	ADJ
cblr-2960	179	18	available	available	ADJ
cblr-2960	179	19	hedge	hedge	NOUN
cblr-2960	179	20	funds	fund	NOUN
cblr-2960	179	21	?	?	PUNCT
cblr-2960	179	22	,	,	PUNCT
cblr-2960	179	23	mfa	mfa	PROPN
cblr-2960	179	24	reporter	reporter	PROPN
cblr-2960	179	25	,	,	PUNCT
cblr-2960	179	26	dec	dec	PROPN
cblr-2960	179	27	.	.	PROPN
cblr-2960	179	28	2004	2004	NUM
cblr-2960	179	29	,	,	PUNCT
cblr-2960	179	30	at	at	ADP
cblr-2960	179	31	10	10	NUM
cblr-2960	179	32	(	(	PUNCT
cblr-2960	179	33	explaining	explain	VERB
cblr-2960	179	34	that	that	SCONJ
cblr-2960	179	35	policy	policy	NOUN
cblr-2960	179	36	owners	owner	NOUN
cblr-2960	179	37	can	can	AUX
cblr-2960	179	38	not	not	PART
cblr-2960	179	39	direct	direct	VERB
cblr-2960	179	40	the	the	DET
cblr-2960	179	41	investments	investment	NOUN
cblr-2960	179	42	within	within	ADP
cblr-2960	179	43	their	their	PRON
cblr-2960	179	44	policies	policy	NOUN
cblr-2960	179	45	beyond	beyond	ADP
cblr-2960	179	46	giving	give	VERB
cblr-2960	179	47	basic	basic	ADJ
cblr-2960	179	48	guidance	guidance	NOUN
cblr-2960	179	49	to	to	ADP
cblr-2960	179	50	the	the	DET
cblr-2960	179	51	insurance	insurance	NOUN
cblr-2960	179	52	company	company	NOUN
cblr-2960	179	53	)	)	PUNCT
cblr-2960	179	54	.	.	PUNCT
cblr-2960	180	1	5	5	NUM
cblr-2960	180	2	see	see	VERB
cblr-2960	180	3	markuson	markuson	PROPN
cblr-2960	180	4	,	,	PUNCT
cblr-2960	180	5	supra	supra	PROPN
cblr-2960	180	6	note	note	PROPN
cblr-2960	180	7	4	4	NUM
cblr-2960	180	8	,	,	PUNCT
cblr-2960	180	9	at	at	ADP
cblr-2960	180	10	5	5	NUM
cblr-2960	180	11	(	(	PUNCT
cblr-2960	180	12	noting	note	VERB
cblr-2960	180	13	that	that	SCONJ
cblr-2960	180	14	the	the	DET
cblr-2960	180	15	policyholder	policyholder	NOUN
cblr-2960	180	16	can	can	AUX
cblr-2960	180	17	not	not	PART
cblr-2960	180	18	possess	possess	VERB
cblr-2960	180	19	sufficient	sufficient	ADJ
cblr-2960	180	20	incidents	incident	NOUN
cblr-2960	180	21	of	of	ADP
cblr-2960	180	22	ownership	ownership	NOUN
cblr-2960	180	23	of	of	ADP
cblr-2960	180	24	the	the	DET
cblr-2960	180	25	segregated	segregated	ADJ
cblr-2960	180	26	assets	asset	NOUN
cblr-2960	180	27	or	or	CCONJ
cblr-2960	180	28	else	else	ADV
cblr-2960	180	29	will	will	AUX
cblr-2960	180	30	risk	risk	VERB
cblr-2960	180	31	forfeiting	forfeit	VERB
cblr-2960	180	32	the	the	DET
cblr-2960	180	33	tax	tax	NOUN
cblr-2960	180	34	advantages	advantage	NOUN
cblr-2960	180	35	of	of	ADP
cblr-2960	180	36	the	the	DET
cblr-2960	180	37	policy	policy	NOUN
cblr-2960	180	38	)	)	PUNCT
cblr-2960	180	39	.	.	PUNCT
cblr-2960	181	1	no	no	INTJ
cblr-2960	181	2	.	.	PUNCT
cblr-2960	182	1	2:694	2:694	NUM
cblr-2960	182	2	]	]	X
cblr-2960	182	3	in	in	ADP
cblr-2960	182	4	revenue	revenue	NOUN
cblr-2960	182	5	ruling	ruling	NOUN
cblr-2960	182	6	2003	2003	NUM
cblr-2960	182	7	-	-	SYM
cblr-2960	182	8	91	91	NUM
cblr-2960	182	9	,	,	PUNCT
cblr-2960	182	10	the	the	DET
cblr-2960	182	11	irs	irs	PROPN
cblr-2960	182	12	respected	respect	VERB
cblr-2960	182	13	the	the	DET
cblr-2960	182	14	insurance	insurance	NOUN
cblr-2960	182	15	company	company	NOUN
cblr-2960	182	16	as	as	ADP
cblr-2960	182	17	the	the	DET
cblr-2960	182	18	owner	owner	NOUN
cblr-2960	182	19	of	of	ADP
cblr-2960	182	20	the	the	DET
cblr-2960	182	21	underlying	underlie	VERB
cblr-2960	182	22	investment	investment	NOUN
cblr-2960	182	23	because	because	SCONJ
cblr-2960	182	24	the	the	DET
cblr-2960	182	25	policyholder	policyholder	NOUN
cblr-2960	182	26	did	do	AUX
cblr-2960	182	27	not	not	PART
cblr-2960	182	28	make	make	VERB
cblr-2960	182	29	particular	particular	ADJ
cblr-2960	182	30	investment	investment	NOUN
cblr-2960	182	31	decisions	decision	NOUN
cblr-2960	182	32	regarding	regard	VERB
cblr-2960	182	33	investments	investment	NOUN
cblr-2960	182	34	in	in	ADP
cblr-2960	182	35	the	the	DET
cblr-2960	182	36	subaccounts.57	subaccounts.57	PROPN
cblr-2960	183	1	the	the	DET
cblr-2960	183	2	ruling	rule	VERB
cblr-2960	183	3	further	further	ADJ
cblr-2960	183	4	states	state	NOUN
cblr-2960	183	5	that	that	SCONJ
cblr-2960	183	6	whether	whether	SCONJ
cblr-2960	183	7	a	a	DET
cblr-2960	183	8	contract	contract	NOUN
cblr-2960	183	9	holder	holder	NOUN
cblr-2960	183	10	has	have	AUX
cblr-2960	183	11	sufficient	sufficient	ADJ
cblr-2960	183	12	ownership	ownership	NOUN
cblr-2960	183	13	to	to	PART
cblr-2960	183	14	cause	cause	VERB
cblr-2960	183	15	him	he	PRON
cblr-2960	183	16	to	to	PART
cblr-2960	183	17	be	be	AUX
cblr-2960	183	18	the	the	DET
cblr-2960	183	19	owner	owner	NOUN
cblr-2960	183	20	of	of	ADP
cblr-2960	183	21	the	the	DET
cblr-2960	183	22	assets	asset	NOUN
cblr-2960	183	23	for	for	ADP
cblr-2960	183	24	federal	federal	ADJ
cblr-2960	183	25	income	income	NOUN
cblr-2960	183	26	tax	tax	NOUN
cblr-2960	183	27	purposes	purpose	NOUN
cblr-2960	183	28	depends	depend	VERB
cblr-2960	183	29	on	on	ADP
cblr-2960	183	30	all	all	PRON
cblr-2960	183	31	of	of	ADP
cblr-2960	183	32	the	the	DET
cblr-2960	183	33	relevant	relevant	ADJ
cblr-2960	183	34	facts	fact	NOUN
cblr-2960	183	35	and	and	CCONJ
cblr-2960	183	36	circumstances.58	circumstances.58	VERB
cblr-2960	183	37	the	the	DET
cblr-2960	183	38	irs	irs	PROPN
cblr-2960	183	39	ruled	rule	VERB
cblr-2960	183	40	that	that	SCONJ
cblr-2960	183	41	that	that	SCONJ
cblr-2960	183	42	the	the	DET
cblr-2960	183	43	policyholder	policyholder	NOUN
cblr-2960	183	44	did	do	AUX
cblr-2960	183	45	not	not	PART
cblr-2960	183	46	have	have	VERB
cblr-2960	183	47	direct	direct	ADJ
cblr-2960	183	48	or	or	CCONJ
cblr-2960	183	49	indirect	indirect	ADJ
cblr-2960	183	50	control	control	NOUN
cblr-2960	183	51	over	over	ADP
cblr-2960	183	52	the	the	DET
cblr-2960	183	53	separate	separate	ADJ
cblr-2960	183	54	account	account	NOUN
cblr-2960	183	55	or	or	CCONJ
cblr-2960	183	56	any	any	DET
cblr-2960	183	57	sub	sub	ADJ
cblr-2960	183	58	-	-	ADJ
cblr-2960	183	59	account	account	ADJ
cblr-2960	183	60	asset	asset	NOUN
cblr-2960	183	61	.	.	PUNCT
cblr-2960	184	1	9	9	NUM
cblr-2960	184	2	the	the	DET
cblr-2960	184	3	ruling	ruling	NOUN
cblr-2960	184	4	also	also	ADV
cblr-2960	184	5	confirmed	confirm	VERB
cblr-2960	184	6	the	the	DET
cblr-2960	184	7	second	second	ADJ
cblr-2960	184	8	principle	principle	NOUN
cblr-2960	184	9	of	of	ADP
cblr-2960	184	10	the	the	DET
cblr-2960	184	11	investor	investor	NOUN
cblr-2960	184	12	control	control	NOUN
cblr-2960	184	13	doctrine	doctrine	NOUN
cblr-2960	184	14	,	,	PUNCT
cblr-2960	184	15	indicating	indicate	VERB
cblr-2960	184	16	that	that	SCONJ
cblr-2960	184	17	owners	owner	NOUN
cblr-2960	184	18	of	of	ADP
cblr-2960	184	19	variable	variable	ADJ
cblr-2960	184	20	life	life	NOUN
cblr-2960	184	21	insurance	insurance	NOUN
cblr-2960	184	22	may	may	AUX
cblr-2960	184	23	allocate	allocate	VERB
cblr-2960	184	24	investments	investment	NOUN
cblr-2960	184	25	among	among	ADP
cblr-2960	184	26	a	a	DET
cblr-2960	184	27	limited	limited	ADJ
cblr-2960	184	28	number	number	NOUN
cblr-2960	184	29	of	of	ADP
cblr-2960	184	30	insurance	insurance	NOUN
cblr-2960	184	31	-	-	PUNCT
cblr-2960	184	32	dedicated	dedicate	VERB
cblr-2960	184	33	"	"	PUNCT
cblr-2960	184	34	funds	fund	NOUN
cblr-2960	184	35	without	without	ADP
cblr-2960	184	36	being	be	AUX
cblr-2960	184	37	the	the	DET
cblr-2960	184	38	owner	owner	NOUN
cblr-2960	184	39	of	of	ADP
cblr-2960	184	40	the	the	DET
cblr-2960	184	41	contract	contract	NOUN
cblr-2960	184	42	for	for	ADP
cblr-2960	184	43	federal	federal	ADJ
cblr-2960	184	44	income	income	NOUN
cblr-2960	184	45	tax	tax	NOUN
cblr-2960	184	46	purposes	purpose	NOUN
cblr-2960	184	47	.	.	PUNCT
cblr-2960	185	1	1	1	NUM
cblr-2960	185	2	2	2	NUM
cblr-2960	185	3	.	.	PUNCT
cblr-2960	186	1	the	the	DET
cblr-2960	186	2	second	second	ADJ
cblr-2960	186	3	prong	prong	NOUN
cblr-2960	186	4	-	-	PUNCT
cblr-2960	186	5	insurance	insurance	NOUN
cblr-2960	186	6	-	-	PUNCT
cblr-2960	186	7	dedicated	dedicate	VERB
cblr-2960	186	8	funds	fund	NOUN
cblr-2960	186	9	only	only	ADV
cblr-2960	186	10	the	the	DET
cblr-2960	186	11	second	second	ADJ
cblr-2960	186	12	prong	prong	NOUN
cblr-2960	186	13	of	of	ADP
cblr-2960	186	14	the	the	DET
cblr-2960	186	15	investor	investor	NOUN
cblr-2960	186	16	control	control	NOUN
cblr-2960	186	17	doctrine	doctrine	NOUN
cblr-2960	186	18	reflected	reflect	VERB
cblr-2960	186	19	the	the	DET
cblr-2960	186	20	service	service	NOUN
cblr-2960	186	21	's	's	PART
cblr-2960	186	22	position	position	NOUN
cblr-2960	186	23	that	that	SCONJ
cblr-2960	186	24	underlying	underlie	VERB
cblr-2960	186	25	investments	investment	NOUN
cblr-2960	186	26	in	in	ADP
cblr-2960	186	27	the	the	DET
cblr-2960	186	28	separate	separate	ADJ
cblr-2960	186	29	accounts	account	NOUN
cblr-2960	186	30	must	must	AUX
cblr-2960	186	31	be	be	AUX
cblr-2960	186	32	accessed	access	VERB
cblr-2960	186	33	only	only	ADV
cblr-2960	186	34	through	through	ADP
cblr-2960	186	35	the	the	DET
cblr-2960	186	36	7	7	NUM
cblr-2960	186	37	see	see	VERB
cblr-2960	186	38	needham	needham	PROPN
cblr-2960	186	39	&	&	CCONJ
cblr-2960	186	40	brause	brause	PROPN
cblr-2960	186	41	,	,	PUNCT
cblr-2960	186	42	supra	supra	PROPN
cblr-2960	186	43	note	note	PROPN
cblr-2960	186	44	53	53	NUM
cblr-2960	186	45	,	,	PUNCT
cblr-2960	186	46	at	at	ADP
cblr-2960	186	47	a-100	a-100	PROPN
cblr-2960	186	48	.	.	PUNCT
cblr-2960	187	1	rev	rev	PROPN
cblr-2960	187	2	.	.	PROPN
cblr-2960	187	3	rul	rul	PROPN
cblr-2960	187	4	.	.	PUNCT
cblr-2960	187	5	2003	2003	NUM
cblr-2960	187	6	-	-	SYM
cblr-2960	187	7	91	91	NUM
cblr-2960	187	8	.	.	PUNCT
cblr-2960	187	9	5	5	NUM
cblr-2960	188	1	the	the	DET
cblr-2960	188	2	irs	irs	PROPN
cblr-2960	188	3	noted	note	VERB
cblr-2960	188	4	that	that	SCONJ
cblr-2960	188	5	the	the	DET
cblr-2960	188	6	investment	investment	NOUN
cblr-2960	188	7	strategies	strategy	NOUN
cblr-2960	188	8	of	of	ADP
cblr-2960	188	9	the	the	DET
cblr-2960	188	10	sub	sub	NOUN
cblr-2960	188	11	-	-	NOUN
cblr-2960	188	12	accounts	account	NOUN
cblr-2960	188	13	are	be	AUX
cblr-2960	188	14	sufficiently	sufficiently	ADV
cblr-2960	188	15	broad	broad	ADJ
cblr-2960	188	16	to	to	PART
cblr-2960	188	17	prevent	prevent	VERB
cblr-2960	188	18	the	the	DET
cblr-2960	188	19	policyholder	policyholder	NOUN
cblr-2960	188	20	from	from	ADP
cblr-2960	188	21	making	make	VERB
cblr-2960	188	22	particular	particular	ADJ
cblr-2960	188	23	investment	investment	NOUN
cblr-2960	188	24	decisions	decision	NOUN
cblr-2960	188	25	;	;	PUNCT
cblr-2960	188	26	that	that	SCONJ
cblr-2960	188	27	no	no	DET
cblr-2960	188	28	arrangement	arrangement	NOUN
cblr-2960	188	29	,	,	PUNCT
cblr-2960	188	30	plan	plan	NOUN
cblr-2960	188	31	,	,	PUNCT
cblr-2960	188	32	contract	contract	NOUN
cblr-2960	188	33	,	,	PUNCT
cblr-2960	188	34	or	or	CCONJ
cblr-2960	188	35	agreement	agreement	NOUN
cblr-2960	188	36	exists	exist	VERB
cblr-2960	188	37	between	between	ADP
cblr-2960	188	38	the	the	DET
cblr-2960	188	39	policyholder	policyholder	NOUN
cblr-2960	188	40	and	and	CCONJ
cblr-2960	188	41	the	the	DET
cblr-2960	188	42	fund	fund	NOUN
cblr-2960	188	43	advisor	advisor	NOUN
cblr-2960	188	44	;	;	PUNCT
cblr-2960	188	45	and	and	CCONJ
cblr-2960	188	46	that	that	SCONJ
cblr-2960	188	47	the	the	DET
cblr-2960	188	48	policy	policy	NOUN
cblr-2960	188	49	holder	holder	NOUN
cblr-2960	188	50	may	may	AUX
cblr-2960	188	51	not	not	PART
cblr-2960	188	52	communicate	communicate	VERB
cblr-2960	188	53	directly	directly	ADV
cblr-2960	188	54	or	or	CCONJ
cblr-2960	188	55	indirectly	indirectly	ADV
cblr-2960	188	56	with	with	ADP
cblr-2960	188	57	the	the	DET
cblr-2960	188	58	advisor	advisor	NOUN
cblr-2960	188	59	or	or	CCONJ
cblr-2960	188	60	any	any	DET
cblr-2960	188	61	investment	investment	NOUN
cblr-2960	188	62	officers	officer	NOUN
cblr-2960	188	63	concerning	concern	VERB
cblr-2960	188	64	the	the	DET
cblr-2960	188	65	selection	selection	NOUN
cblr-2960	188	66	,	,	PUNCT
cblr-2960	188	67	quality	quality	NOUN
cblr-2960	188	68	,	,	PUNCT
cblr-2960	188	69	or	or	CCONJ
cblr-2960	188	70	rate	rate	NOUN
cblr-2960	188	71	of	of	ADP
cblr-2960	188	72	return	return	NOUN
cblr-2960	188	73	of	of	ADP
cblr-2960	188	74	any	any	DET
cblr-2960	188	75	specific	specific	ADJ
cblr-2960	188	76	investment	investment	NOUN
cblr-2960	188	77	or	or	CCONJ
cblr-2960	188	78	group	group	NOUN
cblr-2960	188	79	of	of	ADP
cblr-2960	188	80	investments	investment	NOUN
cblr-2960	188	81	held	hold	VERB
cblr-2960	188	82	by	by	ADP
cblr-2960	188	83	the	the	DET
cblr-2960	188	84	separate	separate	ADJ
cblr-2960	188	85	account	account	NOUN
cblr-2960	188	86	or	or	CCONJ
cblr-2960	188	87	in	in	ADP
cblr-2960	188	88	a	a	DET
cblr-2960	188	89	sub	sub	NOUN
cblr-2960	188	90	-	-	NOUN
cblr-2960	188	91	account	account	NOUN
cblr-2960	188	92	.	.	PUNCT
cblr-2960	189	1	i	i	PRON
cblr-2960	189	2	d.	d.	PROPN
cblr-2960	189	3	thus	thus	ADV
cblr-2960	189	4	,	,	PUNCT
cblr-2960	189	5	all	all	DET
cblr-2960	189	6	investment	investment	NOUN
cblr-2960	189	7	decisions	decision	NOUN
cblr-2960	189	8	concerning	concern	VERB
cblr-2960	189	9	the	the	DET
cblr-2960	189	10	separate	separate	ADJ
cblr-2960	189	11	account	account	NOUN
cblr-2960	189	12	and	and	CCONJ
cblr-2960	189	13	the	the	DET
cblr-2960	189	14	sub	sub	NOUN
cblr-2960	189	15	-	-	ADJ
cblr-2960	189	16	accounts	account	NOUN
cblr-2960	189	17	are	be	AUX
cblr-2960	189	18	made	make	VERB
cblr-2960	189	19	by	by	ADP
cblr-2960	189	20	the	the	DET
cblr-2960	189	21	insurance	insurance	NOUN
cblr-2960	189	22	company	company	NOUN
cblr-2960	189	23	or	or	CCONJ
cblr-2960	189	24	the	the	DET
cblr-2960	189	25	advisor	advisor	NOUN
cblr-2960	189	26	"	"	PUNCT
cblr-2960	189	27	in	in	ADP
cblr-2960	189	28	their	their	PRON
cblr-2960	189	29	sole	sole	ADJ
cblr-2960	189	30	and	and	CCONJ
cblr-2960	189	31	absolute	absolute	ADJ
cblr-2960	189	32	discretion	discretion	NOUN
cblr-2960	189	33	.	.	PUNCT
cblr-2960	189	34	"	"	PUNCT
cblr-2960	190	1	i	i	PRON
cblr-2960	190	2	d.	d.	PROPN
cblr-2960	190	3	'	'	PART
cblr-2960	190	4	insurance	insurance	NOUN
cblr-2960	190	5	-	-	PUNCT
cblr-2960	190	6	dedicated	dedicate	VERB
cblr-2960	190	7	signifies	signifie	NOUN
cblr-2960	190	8	that	that	SCONJ
cblr-2960	190	9	the	the	DET
cblr-2960	190	10	underlying	underlie	VERB
cblr-2960	190	11	investment	investment	NOUN
cblr-2960	190	12	or	or	CCONJ
cblr-2960	190	13	hedge	hedge	NOUN
cblr-2960	190	14	fund	fund	NOUN
cblr-2960	190	15	may	may	AUX
cblr-2960	190	16	be	be	AUX
cblr-2960	190	17	invested	invest	VERB
cblr-2960	190	18	in	in	ADP
cblr-2960	190	19	only	only	ADV
cblr-2960	190	20	through	through	ADP
cblr-2960	190	21	the	the	DET
cblr-2960	190	22	purchase	purchase	NOUN
cblr-2960	190	23	of	of	ADP
cblr-2960	190	24	a	a	DET
cblr-2960	190	25	life	life	NOUN
cblr-2960	190	26	insurance	insurance	NOUN
cblr-2960	190	27	policy	policy	NOUN
cblr-2960	190	28	.	.	PUNCT
cblr-2960	191	1	61	61	NUM
cblr-2960	191	2	rev	rev	X
cblr-2960	191	3	.	.	PUNCT
cblr-2960	191	4	rul	rul	PROPN
cblr-2960	191	5	.	.	PUNCT
cblr-2960	191	6	2003	2003	NUM
cblr-2960	191	7	-	-	SYM
cblr-2960	191	8	91	91	NUM
cblr-2960	191	9	(	(	PUNCT
cblr-2960	191	10	indicating	indicate	VERB
cblr-2960	191	11	that	that	SCONJ
cblr-2960	191	12	investment	investment	NOUN
cblr-2960	191	13	sub	sub	NOUN
cblr-2960	191	14	-	-	NOUN
cblr-2960	191	15	accounts	account	NOUN
cblr-2960	191	16	are	be	AUX
cblr-2960	191	17	available	available	ADJ
cblr-2960	191	18	solely	solely	ADV
cblr-2960	191	19	through	through	ADP
cblr-2960	191	20	the	the	DET
cblr-2960	191	21	purchase	purchase	NOUN
cblr-2960	191	22	of	of	ADP
cblr-2960	191	23	a	a	DET
cblr-2960	191	24	contract	contract	NOUN
cblr-2960	191	25	and	and	CCONJ
cblr-2960	191	26	thus	thus	ADV
cblr-2960	191	27	the	the	DET
cblr-2960	191	28	subaccounts	subaccount	NOUN
cblr-2960	191	29	are	be	AUX
cblr-2960	191	30	not	not	PART
cblr-2960	191	31	publicly	publicly	ADV
cblr-2960	191	32	available	available	ADJ
cblr-2960	191	33	)	)	PUNCT
cblr-2960	191	34	.	.	PUNCT
cblr-2960	192	1	[	[	X
cblr-2960	192	2	vol	vol	NOUN
cblr-2960	192	3	.	.	PUNCT
cblr-2960	192	4	2008columiab	2008columiab	NUM
cblr-2960	192	5	business	business	NOUN
cblr-2960	192	6	la	la	PROPN
cblr-2960	192	7	w	w	PROPN
cblr-2960	192	8	re	re	PROPN
cblr-2960	192	9	vie	vie	PROPN
cblr-2960	192	10	w	w	PROPN
cblr-2960	192	11	job	job	NOUN
cblr-2960	192	12	well	well	ADV
cblr-2960	192	13	done	do	VERB
cblr-2960	192	14	purchase	purchase	NOUN
cblr-2960	192	15	of	of	ADP
cblr-2960	192	16	an	an	DET
cblr-2960	192	17	annuity	annuity	NOUN
cblr-2960	192	18	or	or	CCONJ
cblr-2960	192	19	life	life	NOUN
cblr-2960	192	20	insurance	insurance	NOUN
cblr-2960	192	21	contract	contract	NOUN
cblr-2960	192	22	2	2	NUM
cblr-2960	192	23	however	however	ADV
cblr-2960	192	24	,	,	PUNCT
cblr-2960	192	25	treasury	treasury	NOUN
cblr-2960	192	26	regulation	regulation	NOUN
cblr-2960	192	27	section	section	NOUN
cblr-2960	192	28	1.817	1.817	NUM
cblr-2960	192	29	-	-	SYM
cblr-2960	192	30	5(f)(2)(ii	5(f)(2)(ii	NUM
cblr-2960	192	31	)	)	PUNCT
cblr-2960	192	32	,	,	PUNCT
cblr-2960	192	33	which	which	PRON
cblr-2960	192	34	was	be	AUX
cblr-2960	192	35	enacted	enact	VERB
cblr-2960	192	36	with	with	ADP
cblr-2960	192	37	section	section	NOUN
cblr-2960	192	38	817	817	NUM
cblr-2960	192	39	,	,	PUNCT
cblr-2960	192	40	made	make	VERB
cblr-2960	192	41	an	an	DET
cblr-2960	192	42	exception	exception	NOUN
cblr-2960	192	43	for	for	ADP
cblr-2960	192	44	nonregistered	nonregistered	ADJ
cblr-2960	192	45	partnerships	partnership	NOUN
cblr-2960	192	46	like	like	ADP
cblr-2960	192	47	hedge	hedge	NOUN
cblr-2960	192	48	funds	fund	NOUN
cblr-2960	192	49	,	,	PUNCT
cblr-2960	192	50	allowing	allow	VERB
cblr-2960	192	51	lookthrough	lookthrough	ADJ
cblr-2960	192	52	treatment	treatment	NOUN
cblr-2960	192	53	even	even	ADV
cblr-2960	192	54	if	if	SCONJ
cblr-2960	192	55	the	the	DET
cblr-2960	192	56	hedge	hedge	NOUN
cblr-2960	192	57	fund	fund	NOUN
cblr-2960	192	58	investment	investment	NOUN
cblr-2960	192	59	was	be	AUX
cblr-2960	192	60	not	not	PART
cblr-2960	192	61	insurance	insurance	NOUN
cblr-2960	192	62	-	-	PUNCT
cblr-2960	192	63	dedicated	dedicate	VERB
cblr-2960	192	64	.	.	PUNCT
cblr-2960	192	65	'	'	PUNCT
cblr-2960	193	1	yet	yet	ADV
cblr-2960	193	2	,	,	PUNCT
cblr-2960	193	3	private	private	ADJ
cblr-2960	193	4	letter	letter	NOUN
cblr-2960	193	5	ruling	rule	VERB
cblr-2960	193	6	200244	200244	NUM
cblr-2960	193	7	-	-	SYM
cblr-2960	193	8	001	001	NOUN
cblr-2960	193	9	,	,	PUNCT
cblr-2960	193	10	the	the	DET
cblr-2960	193	11	later	later	ADJ
cblr-2960	193	12	removal	removal	NOUN
cblr-2960	193	13	of	of	ADP
cblr-2960	193	14	regulation	regulation	NOUN
cblr-2960	193	15	section	section	NOUN
cblr-2960	193	16	1.8175(f)(2)(ii	1.8175(f)(2)(ii	NUM
cblr-2960	193	17	)	)	PUNCT
cblr-2960	193	18	,	,	PUNCT
cblr-2960	193	19	and	and	CCONJ
cblr-2960	193	20	revenue	revenue	NOUN
cblr-2960	193	21	ruling	ruling	NOUN
cblr-2960	193	22	2003	2003	NUM
cblr-2960	193	23	-	-	SYM
cblr-2960	193	24	02	02	NUM
cblr-2960	193	25	extend	extend	VERB
cblr-2960	193	26	the	the	DET
cblr-2960	193	27	second	second	ADJ
cblr-2960	193	28	prong	prong	NOUN
cblr-2960	193	29	of	of	ADP
cblr-2960	193	30	the	the	DET
cblr-2960	193	31	investor	investor	NOUN
cblr-2960	193	32	control	control	NOUN
cblr-2960	193	33	doctrine	doctrine	NOUN
cblr-2960	193	34	to	to	PART
cblr-2960	193	35	hedge	hedge	VERB
cblr-2960	193	36	funds	fund	NOUN
cblr-2960	193	37	as	as	ADV
cblr-2960	193	38	well	well	ADV
cblr-2960	193	39	.	.	PUNCT
cblr-2960	193	40	'	'	PUNCT
cblr-2960	194	1	thus	thus	ADV
cblr-2960	194	2	,	,	PUNCT
cblr-2960	194	3	due	due	ADP
cblr-2960	194	4	to	to	ADP
cblr-2960	194	5	recent	recent	ADJ
cblr-2960	194	6	reform	reform	NOUN
cblr-2960	194	7	efforts	effort	NOUN
cblr-2960	194	8	,	,	PUNCT
cblr-2960	194	9	a	a	DET
cblr-2960	194	10	hedge	hedge	NOUN
cblr-2960	194	11	fund	fund	NOUN
cblr-2960	194	12	is	be	AUX
cblr-2960	194	13	accessible	accessible	ADJ
cblr-2960	194	14	only	only	ADV
cblr-2960	194	15	through	through	ADP
cblr-2960	194	16	an	an	DET
cblr-2960	194	17	insurance	insurance	NOUN
cblr-2960	194	18	-	-	PUNCT
cblr-2960	194	19	dedicated	dedicate	VERB
cblr-2960	194	20	fund	fund	NOUN
cblr-2960	194	21	and	and	CCONJ
cblr-2960	194	22	any	any	DET
cblr-2960	194	23	investment	investment	NOUN
cblr-2960	194	24	by	by	ADP
cblr-2960	194	25	a	a	DET
cblr-2960	194	26	variable	variable	ADJ
cblr-2960	194	27	contract	contract	NOUN
cblr-2960	194	28	in	in	ADP
cblr-2960	194	29	a	a	DET
cblr-2960	194	30	fund	fund	NOUN
cblr-2960	194	31	that	that	PRON
cblr-2960	194	32	is	be	AUX
cblr-2960	194	33	also	also	ADV
cblr-2960	194	34	open	open	ADJ
cblr-2960	194	35	to	to	ADP
cblr-2960	194	36	the	the	DET
cblr-2960	194	37	general	general	ADJ
cblr-2960	194	38	public	public	NOUN
cblr-2960	194	39	is	be	AUX
cblr-2960	194	40	absolutely	absolutely	ADV
cblr-2960	194	41	forbidden.65	forbidden.65	NOUN
cblr-2960	194	42	a.	a.	NOUN
cblr-2960	194	43	private	private	ADJ
cblr-2960	194	44	letter	letter	NOUN
cblr-2960	194	45	ruling	rule	VERB
cblr-2960	194	46	2002	2002	NUM
cblr-2960	194	47	-	-	SYM
cblr-2960	194	48	44	44	NUM
cblr-2960	194	49	-	-	PUNCT
cblr-2960	194	50	001	001	NOUN
cblr-2960	194	51	in	in	ADP
cblr-2960	194	52	private	private	ADJ
cblr-2960	194	53	letter	letter	NOUN
cblr-2960	194	54	ruling	rule	VERB
cblr-2960	194	55	2002	2002	NUM
cblr-2960	194	56	-	-	SYM
cblr-2960	194	57	44	44	NUM
cblr-2960	194	58	-	-	PUNCT
cblr-2960	194	59	001	001	NUM
cblr-2960	194	60	(	(	PUNCT
cblr-2960	194	61	"	"	PUNCT
cblr-2960	194	62	plr	plr	NOUN
cblr-2960	194	63	2002	2002	NUM
cblr-2960	194	64	-	-	SYM
cblr-2960	194	65	44001	44001	NUM
cblr-2960	194	66	"	"	PUNCT
cblr-2960	194	67	)	)	PUNCT
cblr-2960	194	68	,	,	PUNCT
cblr-2960	194	69	the	the	DET
cblr-2960	194	70	service	service	NOUN
cblr-2960	194	71	ruled	rule	VERB
cblr-2960	194	72	that	that	SCONJ
cblr-2960	194	73	life	life	NOUN
cblr-2960	194	74	insurance	insurance	NOUN
cblr-2960	194	75	companies	company	NOUN
cblr-2960	194	76	that	that	PRON
cblr-2960	194	77	offer	offer	VERB
cblr-2960	194	78	hedge	hedge	NOUN
cblr-2960	194	79	funds	fund	NOUN
cblr-2960	194	80	as	as	ADP
cblr-2960	194	81	an	an	DET
cblr-2960	194	82	investment	investment	NOUN
cblr-2960	194	83	choice	choice	NOUN
cblr-2960	194	84	for	for	ADP
cblr-2960	194	85	variable	variable	ADJ
cblr-2960	194	86	contracts	contract	NOUN
cblr-2960	194	87	are	be	AUX
cblr-2960	194	88	restricted	restrict	VERB
cblr-2960	194	89	to	to	ADP
cblr-2960	194	90	offering	offer	VERB
cblr-2960	194	91	hedge	hedge	NOUN
cblr-2960	194	92	funds	fund	NOUN
cblr-2960	194	93	in	in	ADP
cblr-2960	194	94	which	which	PRON
cblr-2960	194	95	only	only	ADV
cblr-2960	194	96	life	life	NOUN
cblr-2960	194	97	insurance	insurance	NOUN
cblr-2960	194	98	companies	company	NOUN
cblr-2960	194	99	can	can	AUX
cblr-2960	194	100	participate.6	participate.6	VERB
cblr-2960	194	101	insurance	insurance	NOUN
cblr-2960	194	102	62	62	NUM
cblr-2960	194	103	see	see	NOUN
cblr-2960	194	104	rev	rev	PROPN
cblr-2960	194	105	.	.	PROPN
cblr-2960	195	1	rul	rul	PROPN
cblr-2960	195	2	.	.	PUNCT
cblr-2960	196	1	81	81	NUM
cblr-2960	196	2	-	-	SYM
cblr-2960	196	3	225	225	NUM
cblr-2960	196	4	(	(	PUNCT
cblr-2960	196	5	ruling	rule	VERB
cblr-2960	196	6	that	that	SCONJ
cblr-2960	196	7	investment	investment	NOUN
cblr-2960	196	8	in	in	ADP
cblr-2960	196	9	a	a	DET
cblr-2960	196	10	fund	fund	NOUN
cblr-2960	196	11	that	that	PRON
cblr-2960	196	12	is	be	AUX
cblr-2960	196	13	open	open	ADJ
cblr-2960	196	14	to	to	ADP
cblr-2960	196	15	the	the	DET
cblr-2960	196	16	general	general	ADJ
cblr-2960	196	17	public	public	NOUN
cblr-2960	196	18	is	be	AUX
cblr-2960	196	19	prohibited	prohibit	VERB
cblr-2960	196	20	because	because	SCONJ
cblr-2960	196	21	the	the	DET
cblr-2960	196	22	policyholder	policyholder	NOUN
cblr-2960	196	23	's	's	PART
cblr-2960	196	24	positions	position	NOUN
cblr-2960	196	25	are	be	AUX
cblr-2960	196	26	substantially	substantially	ADV
cblr-2960	196	27	identical	identical	ADJ
cblr-2960	196	28	to	to	ADP
cblr-2960	196	29	what	what	PRON
cblr-2960	196	30	his	his	PRON
cblr-2960	196	31	or	or	CCONJ
cblr-2960	196	32	her	her	PRON
cblr-2960	196	33	position	position	NOUN
cblr-2960	196	34	would	would	AUX
cblr-2960	196	35	have	have	AUX
cblr-2960	196	36	been	be	AUX
cblr-2960	196	37	had	have	AUX
cblr-2960	196	38	the	the	DET
cblr-2960	196	39	fund	fund	NOUN
cblr-2960	196	40	been	be	AUX
cblr-2960	196	41	purchased	purchase	VERB
cblr-2960	196	42	directly	directly	ADV
cblr-2960	196	43	)	)	PUNCT
cblr-2960	196	44	.	.	PUNCT
cblr-2960	197	1	treas	treas	PROPN
cblr-2960	197	2	.	.	PUNCT
cblr-2960	198	1	reg	reg	PROPN
cblr-2960	198	2	.	.	PUNCT
cblr-2960	199	1	§	§	PROPN
cblr-2960	199	2	1.817	1.817	NUM
cblr-2960	199	3	-	-	SYM
cblr-2960	199	4	5(f)(2)(ii	5(f)(2)(ii	NUM
cblr-2960	199	5	)	)	PUNCT
cblr-2960	199	6	(	(	PUNCT
cblr-2960	199	7	repealed	repeal	VERB
cblr-2960	199	8	march	march	PROPN
cblr-2960	199	9	1	1	NUM
cblr-2960	199	10	,	,	PUNCT
cblr-2960	199	11	2005	2005	NUM
cblr-2960	199	12	)	)	PUNCT
cblr-2960	199	13	.	.	PUNCT
cblr-2960	200	1	see	see	VERB
cblr-2960	200	2	i.r.s	i.r.s	NOUN
cblr-2960	200	3	.	.	PUNCT
cblr-2960	201	1	priv	priv	PROPN
cblr-2960	201	2	.	.	PUNCT
cblr-2960	202	1	ltr	ltr	PROPN
cblr-2960	202	2	.	.	PUNCT
cblr-2960	202	3	rul	rul	PROPN
cblr-2960	202	4	.	.	PUNCT
cblr-2960	202	5	2002	2002	NUM
cblr-2960	202	6	-	-	SYM
cblr-2960	202	7	44	44	NUM
cblr-2960	202	8	-	-	PUNCT
cblr-2960	202	9	001	001	NUM
cblr-2960	202	10	(	(	PUNCT
cblr-2960	202	11	may	may	PROPN
cblr-2960	202	12	2	2	NUM
cblr-2960	202	13	,	,	PUNCT
cblr-2960	202	14	2002	2002	NUM
cblr-2960	202	15	)	)	PUNCT
cblr-2960	202	16	;	;	PUNCT
cblr-2960	202	17	internal	internal	ADJ
cblr-2960	202	18	revenue	revenue	NOUN
cblr-2960	202	19	serv	serv	X
cblr-2960	202	20	.	.	PUNCT
cblr-2960	202	21	,	,	PUNCT
cblr-2960	202	22	irs	irs	PROPN
cblr-2960	202	23	publishes	publish	VERB
cblr-2960	202	24	final	final	ADJ
cblr-2960	202	25	regs	reg	NOUN
cblr-2960	202	26	on	on	ADP
cblr-2960	202	27	look	look	NOUN
cblr-2960	202	28	-	-	PUNCT
cblr-2960	202	29	through	through	NOUN
cblr-2960	202	30	for	for	ADP
cblr-2960	202	31	nonregistered	nonregistered	ADJ
cblr-2960	202	32	partnerships	partnership	NOUN
cblr-2960	202	33	,	,	PUNCT
cblr-2960	202	34	2005	2005	NUM
cblr-2960	202	35	tax	tax	NOUN
cblr-2960	202	36	notes	note	VERB
cblr-2960	202	37	39	39	NUM
cblr-2960	202	38	-	-	SYM
cblr-2960	202	39	10	10	NUM
cblr-2960	202	40	(	(	PUNCT
cblr-2960	202	41	2005	2005	NUM
cblr-2960	202	42	)	)	PUNCT
cblr-2960	202	43	(	(	PUNCT
cblr-2960	202	44	effectively	effectively	ADV
cblr-2960	202	45	repealing	repeal	VERB
cblr-2960	202	46	§	§	PROPN
cblr-2960	202	47	1.817	1.817	NUM
cblr-2960	202	48	-	-	SYM
cblr-2960	202	49	5(f)(2)(ii	5(f)(2)(ii	NUM
cblr-2960	202	50	)	)	PUNCT
cblr-2960	202	51	)	)	PUNCT
cblr-2960	203	1	;	;	PUNCT
cblr-2960	203	2	rev	rev	PROPN
cblr-2960	203	3	.	.	PROPN
cblr-2960	204	1	rul	rul	PROPN
cblr-2960	204	2	.	.	PUNCT
cblr-2960	204	3	2003	2003	NUM
cblr-2960	204	4	-	-	SYM
cblr-2960	204	5	92	92	NUM
cblr-2960	204	6	.	.	PUNCT
cblr-2960	205	1	in	in	ADP
cblr-2960	205	2	revenue	revenue	NOUN
cblr-2960	205	3	ruling	rule	VERB
cblr-2960	205	4	200392	200392	NUM
cblr-2960	205	5	,	,	PUNCT
cblr-2960	205	6	a	a	DET
cblr-2960	205	7	separate	separate	ADJ
cblr-2960	205	8	asset	asset	NOUN
cblr-2960	205	9	account	account	NOUN
cblr-2960	205	10	of	of	ADP
cblr-2960	205	11	an	an	DET
cblr-2960	205	12	insurance	insurance	NOUN
cblr-2960	205	13	company	company	NOUN
cblr-2960	205	14	had	have	VERB
cblr-2960	205	15	10	10	NUM
cblr-2960	205	16	subaccounts	subaccount	NOUN
cblr-2960	205	17	,	,	PUNCT
cblr-2960	205	18	each	each	PRON
cblr-2960	205	19	of	of	ADP
cblr-2960	205	20	which	which	PRON
cblr-2960	205	21	invested	invest	VERB
cblr-2960	205	22	in	in	ADP
cblr-2960	205	23	a	a	DET
cblr-2960	205	24	private	private	ADJ
cblr-2960	205	25	investment	investment	NOUN
cblr-2960	205	26	partnership	partnership	NOUN
cblr-2960	205	27	.	.	PUNCT
cblr-2960	206	1	investment	investment	NOUN
cblr-2960	206	2	in	in	ADP
cblr-2960	206	3	the	the	DET
cblr-2960	206	4	partnership	partnership	NOUN
cblr-2960	206	5	was	be	AUX
cblr-2960	206	6	available	available	ADJ
cblr-2960	206	7	to	to	ADP
cblr-2960	206	8	investors	investor	NOUN
cblr-2960	206	9	other	other	ADJ
cblr-2960	206	10	than	than	ADP
cblr-2960	206	11	insurance	insurance	NOUN
cblr-2960	206	12	companies	company	NOUN
cblr-2960	206	13	.	.	PUNCT
cblr-2960	207	1	the	the	DET
cblr-2960	207	2	irs	irs	PROPN
cblr-2960	207	3	ruled	rule	VERB
cblr-2960	207	4	that	that	SCONJ
cblr-2960	207	5	the	the	DET
cblr-2960	207	6	policyholder	policyholder	NOUN
cblr-2960	207	7	,	,	PUNCT
cblr-2960	207	8	not	not	PART
cblr-2960	207	9	the	the	DET
cblr-2960	207	10	insurance	insurance	NOUN
cblr-2960	207	11	company	company	NOUN
cblr-2960	207	12	,	,	PUNCT
cblr-2960	207	13	was	be	AUX
cblr-2960	207	14	the	the	DET
cblr-2960	207	15	owner	owner	NOUN
cblr-2960	207	16	of	of	ADP
cblr-2960	207	17	the	the	DET
cblr-2960	207	18	underlying	underlie	VERB
cblr-2960	207	19	investment	investment	NOUN
cblr-2960	207	20	.	.	PUNCT
cblr-2960	208	1	the	the	DET
cblr-2960	208	2	net	net	ADJ
cblr-2960	208	3	effect	effect	NOUN
cblr-2960	208	4	of	of	ADP
cblr-2960	208	5	revenue	revenue	NOUN
cblr-2960	208	6	ruling	rule	VERB
cblr-2960	208	7	2003	2003	NUM
cblr-2960	208	8	-	-	SYM
cblr-2960	208	9	92	92	NUM
cblr-2960	208	10	is	be	AUX
cblr-2960	208	11	that	that	SCONJ
cblr-2960	208	12	the	the	DET
cblr-2960	208	13	assets	asset	NOUN
cblr-2960	208	14	within	within	ADP
cblr-2960	208	15	variable	variable	ADJ
cblr-2960	208	16	contracts	contract	NOUN
cblr-2960	208	17	may	may	AUX
cblr-2960	208	18	be	be	AUX
cblr-2960	208	19	invested	invest	VERB
cblr-2960	208	20	in	in	ADP
cblr-2960	208	21	hedge	hedge	NOUN
cblr-2960	208	22	funds	fund	NOUN
cblr-2960	208	23	and	and	CCONJ
cblr-2960	208	24	funds	fund	NOUN
cblr-2960	208	25	-	-	PUNCT
cblr-2960	208	26	of	of	ADP
cblr-2960	208	27	-	-	PUNCT
cblr-2960	208	28	funds	fund	NOUN
cblr-2960	208	29	,	,	PUNCT
cblr-2960	208	30	but	but	CCONJ
cblr-2960	208	31	only	only	ADV
cblr-2960	208	32	if	if	SCONJ
cblr-2960	208	33	the	the	DET
cblr-2960	208	34	fund	fund	NOUN
cblr-2960	208	35	is	be	AUX
cblr-2960	208	36	insurance	insurance	NOUN
cblr-2960	208	37	-	-	PUNCT
cblr-2960	208	38	dedicated	dedicate	VERB
cblr-2960	208	39	.	.	PUNCT
cblr-2960	209	1	see	see	VERB
cblr-2960	209	2	neufeld	neufeld	PROPN
cblr-2960	209	3	,	,	PUNCT
cblr-2960	209	4	supra	supra	PROPN
cblr-2960	209	5	note	note	PROPN
cblr-2960	209	6	52	52	NUM
cblr-2960	209	7	,	,	PUNCT
cblr-2960	209	8	at	at	ADP
cblr-2960	209	9	405	405	NUM
cblr-2960	209	10	.	.	PUNCT
cblr-2960	210	1	i.r.s	i.r.s	PROPN
cblr-2960	210	2	.	.	PUNCT
cblr-2960	211	1	priv	priv	PROPN
cblr-2960	211	2	.	.	PUNCT
cblr-2960	212	1	ltr	ltr	PROPN
cblr-2960	212	2	.	.	PUNCT
cblr-2960	212	3	rul	rul	PROPN
cblr-2960	212	4	.	.	PUNCT
cblr-2960	212	5	2002	2002	NUM
cblr-2960	212	6	-	-	SYM
cblr-2960	212	7	44	44	NUM
cblr-2960	212	8	-	-	PUNCT
cblr-2960	212	9	001	001	NUM
cblr-2960	212	10	(	(	PUNCT
cblr-2960	212	11	may	may	PROPN
cblr-2960	212	12	2	2	NUM
cblr-2960	212	13	,	,	PUNCT
cblr-2960	212	14	2002	2002	NUM
cblr-2960	212	15	)	)	PUNCT
cblr-2960	212	16	(	(	PUNCT
cblr-2960	212	17	concluding	conclude	VERB
cblr-2960	212	18	that	that	SCONJ
cblr-2960	212	19	the	the	DET
cblr-2960	212	20	ruling	ruling	NOUN
cblr-2960	212	21	is	be	AUX
cblr-2960	212	22	consistent	consistent	ADJ
cblr-2960	212	23	with	with	ADP
cblr-2960	212	24	congressional	congressional	ADJ
cblr-2960	212	25	intent	intent	NOUN
cblr-2960	212	26	to	to	PART
cblr-2960	212	27	deny	deny	VERB
cblr-2960	212	28	annuity	annuity	NOUN
cblr-2960	212	29	or	or	CCONJ
cblr-2960	212	30	life	life	NOUN
cblr-2960	212	31	no	no	INTJ
cblr-2960	212	32	.	.	PUNCT
cblr-2960	213	1	2:694	2:694	NUM
cblr-2960	213	2	]	]	X
cblr-2960	213	3	company	company	NOUN
cblr-2960	213	4	accounts	account	NOUN
cblr-2960	213	5	can	can	AUX
cblr-2960	213	6	not	not	PART
cblr-2960	213	7	invest	invest	VERB
cblr-2960	213	8	side	side	NOUN
cblr-2960	213	9	-	-	PUNCT
cblr-2960	213	10	by	by	ADP
cblr-2960	213	11	-	-	PUNCT
cblr-2960	213	12	side	side	NOUN
cblr-2960	213	13	in	in	ADP
cblr-2960	213	14	hedge	hedge	NOUN
cblr-2960	213	15	funds	fund	NOUN
cblr-2960	213	16	with	with	ADP
cblr-2960	213	17	wealthy	wealthy	ADJ
cblr-2960	213	18	investors	investor	NOUN
cblr-2960	213	19	from	from	ADP
cblr-2960	213	20	the	the	DET
cblr-2960	213	21	general	general	ADJ
cblr-2960	213	22	public.67	public.67	NOUN
cblr-2960	213	23	according	accord	VERB
cblr-2960	213	24	to	to	ADP
cblr-2960	213	25	the	the	DET
cblr-2960	213	26	ruling	ruling	NOUN
cblr-2960	213	27	,	,	PUNCT
cblr-2960	213	28	a	a	DET
cblr-2960	213	29	hedge	hedge	NOUN
cblr-2960	213	30	fund	fund	NOUN
cblr-2960	213	31	with	with	ADP
cblr-2960	213	32	investors	investor	NOUN
cblr-2960	213	33	other	other	ADJ
cblr-2960	213	34	than	than	ADP
cblr-2960	213	35	investors	investor	NOUN
cblr-2960	213	36	buying	buy	VERB
cblr-2960	213	37	insurance	insurance	NOUN
cblr-2960	213	38	policies	policy	NOUN
cblr-2960	213	39	is	be	AUX
cblr-2960	213	40	too	too	ADV
cblr-2960	213	41	public	public	ADJ
cblr-2960	213	42	,	,	PUNCT
cblr-2960	213	43	so	so	SCONJ
cblr-2960	213	44	that	that	SCONJ
cblr-2960	213	45	the	the	DET
cblr-2960	213	46	policyholder	policyholder	NOUN
cblr-2960	213	47	would	would	AUX
cblr-2960	213	48	be	be	AUX
cblr-2960	213	49	considered	consider	VERB
cblr-2960	213	50	the	the	DET
cblr-2960	213	51	direct	direct	ADJ
cblr-2960	213	52	owner	owner	NOUN
cblr-2960	213	53	of	of	ADP
cblr-2960	213	54	the	the	DET
cblr-2960	213	55	hedge	hedge	NOUN
cblr-2960	213	56	fund	fund	NOUN
cblr-2960	213	57	interest	interest	NOUN
cblr-2960	213	58	;	;	PUNCT
cblr-2960	213	59	that	that	PRON
cblr-2960	213	60	is	be	AUX
cblr-2960	213	61	,	,	PUNCT
cblr-2960	213	62	taxable	taxable	ADJ
cblr-2960	213	63	currently	currently	ADV
cblr-2960	213	64	on	on	ADP
cblr-2960	213	65	the	the	DET
cblr-2960	213	66	fund	fund	NOUN
cblr-2960	213	67	's	's	PART
cblr-2960	213	68	undistributed	undistribute	VERB
cblr-2960	213	69	income.68	income.68	PROPN
cblr-2960	213	70	the	the	DET
cblr-2960	213	71	service	service	NOUN
cblr-2960	213	72	made	make	VERB
cblr-2960	213	73	its	its	PRON
cblr-2960	213	74	ruling	ruling	NOUN
cblr-2960	213	75	in	in	ADP
cblr-2960	213	76	plr	plr	NOUN
cblr-2960	213	77	2002	2002	NUM
cblr-2960	213	78	-	-	SYM
cblr-2960	213	79	44	44	NUM
cblr-2960	213	80	-	-	PUNCT
cblr-2960	213	81	001	001	NUM
cblr-2960	213	82	notwithstanding	notwithstanding	ADP
cblr-2960	213	83	treasury	treasury	NOUN
cblr-2960	213	84	regulation	regulation	NOUN
cblr-2960	213	85	section	section	NOUN
cblr-2960	213	86	1.817	1.817	NUM
cblr-2960	213	87	-	-	SYM
cblr-2960	213	88	5(f)(2)(ii	5(f)(2)(ii	NUM
cblr-2960	213	89	)	)	PUNCT
cblr-2960	213	90	,	,	PUNCT
cblr-2960	213	91	which	which	PRON
cblr-2960	213	92	specifically	specifically	ADV
cblr-2960	213	93	permitted	permit	VERB
cblr-2960	213	94	investors	investor	NOUN
cblr-2960	213	95	other	other	ADJ
cblr-2960	213	96	than	than	ADP
cblr-2960	213	97	insuranceonly	insuranceonly	ADV
cblr-2960	213	98	investors	investor	NOUN
cblr-2960	213	99	in	in	ADP
cblr-2960	213	100	nonregistered	nonregistered	ADJ
cblr-2960	213	101	partnerships	partnership	NOUN
cblr-2960	213	102	.	.	PUNCT
cblr-2960	213	103	"	"	PUNCT
cblr-2960	214	1	hedge	hedge	NOUN
cblr-2960	214	2	funds	fund	NOUN
cblr-2960	214	3	are	be	AUX
cblr-2960	214	4	typically	typically	ADV
cblr-2960	214	5	structured	structure	VERB
cblr-2960	214	6	as	as	ADP
cblr-2960	214	7	nonregistered	nonregistered	ADJ
cblr-2960	214	8	partnerships	partnership	NOUN
cblr-2960	214	9	and	and	CCONJ
cblr-2960	214	10	,	,	PUNCT
cblr-2960	214	11	therefore	therefore	ADV
cblr-2960	214	12	,	,	PUNCT
cblr-2960	214	13	under	under	ADP
cblr-2960	214	14	section	section	NOUN
cblr-2960	214	15	1.817	1.817	NUM
cblr-2960	214	16	-	-	SYM
cblr-2960	214	17	5(f)(2)(ii	5(f)(2)(ii	NUM
cblr-2960	214	18	)	)	PUNCT
cblr-2960	214	19	,	,	PUNCT
cblr-2960	214	20	qualified	qualify	VERB
cblr-2960	214	21	for	for	ADP
cblr-2960	214	22	lookthrough	lookthrough	ADJ
cblr-2960	214	23	treatment	treatment	NOUN
cblr-2960	214	24	for	for	ADP
cblr-2960	214	25	purposes	purpose	NOUN
cblr-2960	214	26	of	of	ADP
cblr-2960	214	27	applying	apply	VERB
cblr-2960	214	28	the	the	DET
cblr-2960	214	29	diversification	diversification	NOUN
cblr-2960	214	30	tests	test	NOUN
cblr-2960	214	31	of	of	ADP
cblr-2960	214	32	section	section	NOUN
cblr-2960	214	33	817(h	817(h	PROPN
cblr-2960	214	34	)	)	PUNCT
cblr-2960	214	35	.	.	PUNCT
cblr-2960	215	1	7	7	NUM
cblr-2960	215	2	'	'	PUNCT
cblr-2960	215	3	nonetheless	nonetheless	ADV
cblr-2960	215	4	,	,	PUNCT
cblr-2960	215	5	the	the	DET
cblr-2960	215	6	service	service	NOUN
cblr-2960	215	7	's	's	PART
cblr-2960	215	8	ruling	ruling	NOUN
cblr-2960	215	9	contradicted	contradict	VERB
cblr-2960	215	10	the	the	DET
cblr-2960	215	11	explicit	explicit	ADJ
cblr-2960	215	12	permission	permission	NOUN
cblr-2960	215	13	granted	grant	VERB
cblr-2960	215	14	in	in	ADP
cblr-2960	215	15	regulation	regulation	NOUN
cblr-2960	215	16	section	section	NOUN
cblr-2960	215	17	1.817	1.817	NUM
cblr-2960	215	18	-	-	SYM
cblr-2960	215	19	5(f)(2)(ii	5(f)(2)(ii	NUM
cblr-2960	215	20	)	)	PUNCT
cblr-2960	215	21	,	,	PUNCT
cblr-2960	215	22	causing	cause	VERB
cblr-2960	215	23	industry	industry	NOUN
cblr-2960	215	24	confusion	confusion	NOUN
cblr-2960	215	25	and	and	CCONJ
cblr-2960	215	26	requiring	require	VERB
cblr-2960	215	27	further	further	ADJ
cblr-2960	215	28	government	government	NOUN
cblr-2960	215	29	action	action	NOUN
cblr-2960	215	30	.	.	PUNCT
cblr-2960	216	1	insurance	insurance	NOUN
cblr-2960	216	2	treatment	treatment	NOUN
cblr-2960	216	3	for	for	ADP
cblr-2960	216	4	investments	investment	NOUN
cblr-2960	216	5	that	that	PRON
cblr-2960	216	6	are	be	AUX
cblr-2960	216	7	publicly	publicly	ADV
cblr-2960	216	8	available	available	ADJ
cblr-2960	216	9	to	to	ADP
cblr-2960	216	10	investors	investor	NOUN
cblr-2960	216	11	)	)	PUNCT
cblr-2960	216	12	.	.	PUNCT
cblr-2960	217	1	67	67	NUM
cblr-2960	217	2	lee	lee	PROPN
cblr-2960	217	3	a.	a.	PROPN
cblr-2960	217	4	sheppard	sheppard	PROPN
cblr-2960	217	5	,	,	PUNCT
cblr-2960	217	6	hedge	hedge	NOUN
cblr-2960	217	7	fund	fund	NOUN
cblr-2960	217	8	wrapper	wrapper	NOUN
cblr-2960	217	9	ruling	ruling	NOUN
cblr-2960	217	10	makes	make	VERB
cblr-2960	217	11	getting	get	VERB
cblr-2960	217	12	smaller	small	ADJ
cblr-2960	217	13	investors	investor	NOUN
cblr-2960	217	14	harder	hard	ADV
cblr-2960	217	15	,	,	PUNCT
cblr-2960	217	16	23	23	NUM
cblr-2960	217	17	ins	in	NOUN
cblr-2960	217	18	.	.	PUNCT
cblr-2960	218	1	tax	tax	NOUN
cblr-2960	218	2	rev	rev	PROPN
cblr-2960	218	3	.	.	PROPN
cblr-2960	219	1	794	794	NUM
cblr-2960	219	2	,	,	PUNCT
cblr-2960	219	3	794	794	NUM
cblr-2960	219	4	(	(	PUNCT
cblr-2960	219	5	2002	2002	NUM
cblr-2960	219	6	)	)	PUNCT
cblr-2960	219	7	(	(	PUNCT
cblr-2960	219	8	insurance	insurance	NOUN
cblr-2960	219	9	companies	company	NOUN
cblr-2960	219	10	can	can	AUX
cblr-2960	219	11	not	not	PART
cblr-2960	219	12	"	"	PUNCT
cblr-2960	219	13	wrap	wrap	VERB
cblr-2960	219	14	"	"	PUNCT
cblr-2960	219	15	hedge	hedge	NOUN
cblr-2960	219	16	fund	fund	NOUN
cblr-2960	219	17	interests	interest	NOUN
cblr-2960	219	18	in	in	ADP
cblr-2960	219	19	insurance	insurance	NOUN
cblr-2960	219	20	products	product	NOUN
cblr-2960	219	21	if	if	SCONJ
cblr-2960	219	22	they	they	PRON
cblr-2960	219	23	want	want	VERB
cblr-2960	219	24	investors	investor	NOUN
cblr-2960	219	25	in	in	ADP
cblr-2960	219	26	their	their	PRON
cblr-2960	219	27	variable	variable	ADJ
cblr-2960	219	28	contracts	contract	NOUN
cblr-2960	219	29	to	to	PART
cblr-2960	219	30	have	have	VERB
cblr-2960	219	31	the	the	DET
cblr-2960	219	32	benefit	benefit	NOUN
cblr-2960	219	33	of	of	ADP
cblr-2960	219	34	the	the	DET
cblr-2960	219	35	tax	tax	NOUN
cblr-2960	219	36	shelter	shelter	NOUN
cblr-2960	219	37	for	for	ADP
cblr-2960	219	38	inside	inside	ADJ
cblr-2960	219	39	buildup	buildup	NOUN
cblr-2960	219	40	)	)	PUNCT
cblr-2960	219	41	.	.	PUNCT
cblr-2960	220	1	6	6	NUM
cblr-2960	220	2	i.r.s	i.r.	NOUN
cblr-2960	220	3	.	.	PUNCT
cblr-2960	221	1	priv	priv	PROPN
cblr-2960	221	2	.	.	PUNCT
cblr-2960	222	1	ltr	ltr	PROPN
cblr-2960	222	2	.	.	PUNCT
cblr-2960	222	3	rul	rul	PROPN
cblr-2960	222	4	.	.	PUNCT
cblr-2960	222	5	2002	2002	NUM
cblr-2960	222	6	-	-	SYM
cblr-2960	222	7	44	44	NUM
cblr-2960	222	8	-	-	PUNCT
cblr-2960	222	9	001	001	NOUN
cblr-2960	222	10	.	.	PUNCT
cblr-2960	223	1	see	see	VERB
cblr-2960	223	2	also	also	ADV
cblr-2960	223	3	i.r.c	i.r.c	NOUN
cblr-2960	223	4	.	.	PUNCT
cblr-2960	224	1	§	§	PROPN
cblr-2960	224	2	61(a	61(a	NUM
cblr-2960	224	3	)	)	PUNCT
cblr-2960	224	4	(	(	PUNCT
cblr-2960	224	5	defining	define	VERB
cblr-2960	224	6	gross	gross	ADJ
cblr-2960	224	7	income	income	NOUN
cblr-2960	224	8	as	as	ADP
cblr-2960	224	9	"	"	PUNCT
cblr-2960	224	10	all	all	DET
cblr-2960	224	11	income	income	NOUN
cblr-2960	224	12	from	from	ADP
cblr-2960	224	13	whatever	whatever	DET
cblr-2960	224	14	source	source	NOUN
cblr-2960	224	15	derived	derive	VERB
cblr-2960	224	16	"	"	PUNCT
cblr-2960	224	17	)	)	PUNCT
cblr-2960	224	18	.	.	PUNCT
cblr-2960	225	1	69	69	NUM
cblr-2960	225	2	see	see	VERB
cblr-2960	225	3	neufeld	neufeld	PROPN
cblr-2960	225	4	,	,	PUNCT
cblr-2960	225	5	supra	supra	PROPN
cblr-2960	225	6	note	note	PROPN
cblr-2960	225	7	42	42	NUM
cblr-2960	225	8	,	,	PUNCT
cblr-2960	225	9	at	at	ADP
cblr-2960	225	10	1192	1192	NUM
cblr-2960	225	11	;	;	PUNCT
cblr-2960	225	12	giordani	giordani	ADJ
cblr-2960	225	13	,	,	PUNCT
cblr-2960	225	14	supra	supra	PROPN
cblr-2960	225	15	note	note	NOUN
cblr-2960	225	16	49	49	NUM
cblr-2960	225	17	(	(	PUNCT
cblr-2960	225	18	noting	note	VERB
cblr-2960	225	19	that	that	SCONJ
cblr-2960	225	20	despite	despite	SCONJ
cblr-2960	225	21	the	the	DET
cblr-2960	225	22	explicit	explicit	ADJ
cblr-2960	225	23	language	language	NOUN
cblr-2960	225	24	regarding	regard	VERB
cblr-2960	225	25	the	the	DET
cblr-2960	225	26	exception	exception	NOUN
cblr-2960	225	27	for	for	ADP
cblr-2960	225	28	nonregistered	nonregistered	ADJ
cblr-2960	225	29	partnerships	partnership	NOUN
cblr-2960	225	30	in	in	ADP
cblr-2960	225	31	relation	relation	NOUN
cblr-2960	225	32	to	to	ADP
cblr-2960	225	33	the	the	DET
cblr-2960	225	34	insurance	insurance	NOUN
cblr-2960	225	35	-	-	PUNCT
cblr-2960	225	36	only	only	ADJ
cblr-2960	225	37	requirement	requirement	NOUN
cblr-2960	225	38	of	of	ADP
cblr-2960	225	39	the	the	DET
cblr-2960	225	40	investor	investor	NOUN
cblr-2960	225	41	control	control	NOUN
cblr-2960	225	42	doctrine	doctrine	NOUN
cblr-2960	225	43	,	,	PUNCT
cblr-2960	225	44	the	the	DET
cblr-2960	225	45	service	service	NOUN
cblr-2960	225	46	has	have	AUX
cblr-2960	225	47	ruled	rule	VERB
cblr-2960	225	48	as	as	SCONJ
cblr-2960	225	49	though	though	SCONJ
cblr-2960	225	50	the	the	DET
cblr-2960	225	51	exception	exception	NOUN
cblr-2960	225	52	does	do	AUX
cblr-2960	225	53	not	not	PART
cblr-2960	225	54	exist	exist	VERB
cblr-2960	225	55	)	)	PUNCT
cblr-2960	225	56	;	;	PUNCT
cblr-2960	225	57	see	see	VERB
cblr-2960	225	58	also	also	ADV
cblr-2960	225	59	i.r.s	i.r.s	NOUN
cblr-2960	225	60	.	.	PUNCT
cblr-2960	226	1	priv	priv	PROPN
cblr-2960	226	2	.	.	PUNCT
cblr-2960	227	1	ltr	ltr	PROPN
cblr-2960	227	2	.	.	PUNCT
cblr-2960	227	3	rul	rul	PROPN
cblr-2960	227	4	.	.	PUNCT
cblr-2960	227	5	2002	2002	NUM
cblr-2960	227	6	-	-	SYM
cblr-2960	227	7	44	44	NUM
cblr-2960	227	8	-	-	PUNCT
cblr-2960	227	9	001	001	NUM
cblr-2960	227	10	(	(	PUNCT
cblr-2960	227	11	holding	hold	VERB
cblr-2960	227	12	any	any	DET
cblr-2960	227	13	investment	investment	NOUN
cblr-2960	227	14	by	by	ADP
cblr-2960	227	15	an	an	DET
cblr-2960	227	16	insurance	insurance	NOUN
cblr-2960	227	17	company	company	NOUN
cblr-2960	227	18	through	through	ADP
cblr-2960	227	19	a	a	DET
cblr-2960	227	20	variable	variable	ADJ
cblr-2960	227	21	policy	policy	NOUN
cblr-2960	227	22	into	into	ADP
cblr-2960	227	23	a	a	DET
cblr-2960	227	24	mutual	mutual	ADJ
cblr-2960	227	25	fund	fund	NOUN
cblr-2960	227	26	or	or	CCONJ
cblr-2960	227	27	a	a	DET
cblr-2960	227	28	hedge	hedge	NOUN
cblr-2960	227	29	fund	fund	NOUN
cblr-2960	227	30	,	,	PUNCT
cblr-2960	227	31	even	even	ADV
cblr-2960	227	32	one	one	NUM
cblr-2960	227	33	established	establish	VERB
cblr-2960	227	34	as	as	ADP
cblr-2960	227	35	a	a	DET
cblr-2960	227	36	nonregistered	nonregistered	ADJ
cblr-2960	227	37	limited	limited	ADJ
cblr-2960	227	38	partnership	partnership	NOUN
cblr-2960	227	39	,	,	PUNCT
cblr-2960	227	40	would	would	AUX
cblr-2960	227	41	violate	violate	VERB
cblr-2960	227	42	the	the	DET
cblr-2960	227	43	investor	investor	NOUN
cblr-2960	227	44	control	control	NOUN
cblr-2960	227	45	rule	rule	NOUN
cblr-2960	227	46	's	's	PART
cblr-2960	227	47	prohibition	prohibition	NOUN
cblr-2960	227	48	on	on	ADP
cblr-2960	227	49	integrating	integrate	VERB
cblr-2960	227	50	public	public	ADJ
cblr-2960	227	51	investors	investor	NOUN
cblr-2960	227	52	with	with	ADP
cblr-2960	227	53	insurance	insurance	NOUN
cblr-2960	227	54	company	company	NOUN
cblr-2960	227	55	investors	investor	NOUN
cblr-2960	227	56	)	)	PUNCT
cblr-2960	227	57	.	.	PUNCT
cblr-2960	228	1	70	70	NUM
cblr-2960	228	2	see	see	VERB
cblr-2960	228	3	giordani	giordani	NOUN
cblr-2960	228	4	,	,	PUNCT
cblr-2960	228	5	supra	supra	PROPN
cblr-2960	228	6	note	note	NOUN
cblr-2960	228	7	49	49	NUM
cblr-2960	228	8	.	.	PUNCT
cblr-2960	229	1	[	[	X
cblr-2960	229	2	vol	vol	NOUN
cblr-2960	229	3	.	.	PUNCT
cblr-2960	230	1	2008col	2008col	NUM
cblr-2960	230	2	umia	umia	NOUN
cblr-2960	230	3	b	b	PROPN
cblr-2960	230	4	usiness	usiness	NOUN
cblr-2960	230	5	la	la	PROPN
cblr-2960	230	6	w	w	PROPN
cblr-2960	230	7	re	re	PROPN
cblr-2960	230	8	vie	vie	PROPN
cblr-2960	230	9	w	w	PROPN
cblr-2960	230	10	job	job	NOUN
cblr-2960	230	11	well	well	ADV
cblr-2960	230	12	done	do	VERB
cblr-2960	230	13	b.	b.	PROPN
cblr-2960	230	14	removal	removal	NOUN
cblr-2960	230	15	of	of	ADP
cblr-2960	230	16	regulation	regulation	NOUN
cblr-2960	230	17	section	section	NOUN
cblr-2960	230	18	1.8175(f)(2)(ii	1.8175(f)(2)(ii	NUM
cblr-2960	230	19	)	)	PUNCT
cblr-2960	230	20	after	after	ADP
cblr-2960	230	21	the	the	DET
cblr-2960	230	22	irs	irs	PROPN
cblr-2960	230	23	's	's	PART
cblr-2960	230	24	ruling	ruling	NOUN
cblr-2960	230	25	in	in	ADP
cblr-2960	230	26	plr	plr	NOUN
cblr-2960	230	27	2002	2002	NUM
cblr-2960	230	28	-	-	SYM
cblr-2960	230	29	44	44	NUM
cblr-2960	230	30	-	-	PUNCT
cblr-2960	230	31	001	001	NUM
cblr-2960	230	32	,	,	PUNCT
cblr-2960	230	33	where	where	SCONJ
cblr-2960	230	34	the	the	DET
cblr-2960	230	35	irs	irs	PROPN
cblr-2960	230	36	explicitly	explicitly	ADV
cblr-2960	230	37	ignored	ignore	VERB
cblr-2960	230	38	section	section	NOUN
cblr-2960	230	39	1.817	1.817	NUM
cblr-2960	230	40	-	-	SYM
cblr-2960	230	41	5(f)(2)(ii	5(f)(2)(ii	NUM
cblr-2960	230	42	)	)	PUNCT
cblr-2960	230	43	,	,	PUNCT
cblr-2960	230	44	the	the	DET
cblr-2960	230	45	irs	irs	PROPN
cblr-2960	230	46	issued	issue	VERB
cblr-2960	230	47	a	a	DET
cblr-2960	230	48	notice	notice	NOUN
cblr-2960	230	49	repealing	repeal	VERB
cblr-2960	230	50	the	the	DET
cblr-2960	230	51	regulation	regulation	NOUN
cblr-2960	230	52	.	.	PUNCT
cblr-2960	231	1	71	71	NUM
cblr-2960	231	2	the	the	DET
cblr-2960	231	3	notice	notice	NOUN
cblr-2960	231	4	explained	explain	VERB
cblr-2960	231	5	that	that	SCONJ
cblr-2960	231	6	section	section	NOUN
cblr-2960	231	7	1.817	1.817	NUM
cblr-2960	231	8	-	-	SYM
cblr-2960	231	9	5(f)(2)(ii	5(f)(2)(ii	NUM
cblr-2960	231	10	)	)	PUNCT
cblr-2960	231	11	was	be	AUX
cblr-2960	231	12	not	not	PART
cblr-2960	231	13	consistent	consistent	ADJ
cblr-2960	231	14	with	with	ADP
cblr-2960	231	15	congressional	congressional	ADJ
cblr-2960	231	16	intent	intent	NOUN
cblr-2960	231	17	because	because	SCONJ
cblr-2960	231	18	it	it	PRON
cblr-2960	231	19	was	be	AUX
cblr-2960	231	20	not	not	PART
cblr-2960	231	21	explicitly	explicitly	ADV
cblr-2960	231	22	subject	subject	ADJ
cblr-2960	231	23	to	to	ADP
cblr-2960	231	24	the	the	DET
cblr-2960	231	25	public	public	ADJ
cblr-2960	231	26	availability	availability	NOUN
cblr-2960	231	27	limitation	limitation	NOUN
cblr-2960	231	28	of	of	ADP
cblr-2960	231	29	section	section	NOUN
cblr-2960	231	30	817(h).72	817(h).72	NUM
cblr-2960	231	31	the	the	DET
cblr-2960	231	32	treasury	treasury	PROPN
cblr-2960	231	33	department	department	PROPN
cblr-2960	231	34	and	and	CCONJ
cblr-2960	231	35	the	the	DET
cblr-2960	231	36	irs	irs	PROPN
cblr-2960	231	37	believed	believe	VERB
cblr-2960	231	38	that	that	SCONJ
cblr-2960	231	39	removal	removal	NOUN
cblr-2960	231	40	of	of	ADP
cblr-2960	231	41	section	section	NOUN
cblr-2960	231	42	1.817	1.817	NUM
cblr-2960	231	43	-	-	SYM
cblr-2960	231	44	5(f)(2)(ii	5(f)(2)(ii	NUM
cblr-2960	231	45	)	)	PUNCT
cblr-2960	231	46	would	would	AUX
cblr-2960	231	47	eliminate	eliminate	VERB
cblr-2960	231	48	any	any	DET
cblr-2960	231	49	possible	possible	ADJ
cblr-2960	231	50	confusion	confusion	NOUN
cblr-2960	231	51	regarding	regard	VERB
cblr-2960	231	52	the	the	DET
cblr-2960	231	53	prohibition	prohibition	NOUN
cblr-2960	231	54	on	on	ADP
cblr-2960	231	55	ownership	ownership	NOUN
cblr-2960	231	56	of	of	ADP
cblr-2960	231	57	interests	interest	NOUN
cblr-2960	231	58	by	by	ADP
cblr-2960	231	59	the	the	DET
cblr-2960	231	60	public	public	NOUN
cblr-2960	231	61	in	in	ADP
cblr-2960	231	62	a	a	DET
cblr-2960	231	63	non	non	ADJ
cblr-2960	231	64	-	-	ADJ
cblr-2960	231	65	registered	registered	ADJ
cblr-2960	231	66	partnership	partnership	NOUN
cblr-2960	231	67	funding	fund	VERB
cblr-2960	231	68	a	a	DET
cblr-2960	231	69	variable	variable	ADJ
cblr-2960	231	70	contract	contract	NOUN
cblr-2960	231	71	.	.	PUNCT
cblr-2960	232	1	73	73	NUM
cblr-2960	233	1	the	the	DET
cblr-2960	233	2	removal	removal	NOUN
cblr-2960	233	3	'	'	PUNCT
cblr-2960	233	4	of	of	ADP
cblr-2960	233	5	section	section	NOUN
cblr-2960	233	6	1.817	1.817	NUM
cblr-2960	233	7	-	-	SYM
cblr-2960	233	8	5(f)(2)(ii	5(f)(2)(ii	NUM
cblr-2960	233	9	)	)	PUNCT
cblr-2960	233	10	put	put	VERB
cblr-2960	233	11	to	to	PART
cblr-2960	233	12	rest	rest	VERB
cblr-2960	233	13	any	any	DET
cblr-2960	233	14	debate	debate	NOUN
cblr-2960	233	15	over	over	ADP
cblr-2960	233	16	whether	whether	SCONJ
cblr-2960	233	17	investment	investment	NOUN
cblr-2960	233	18	in	in	ADP
cblr-2960	233	19	a	a	DET
cblr-2960	233	20	nonregistered	nonregistered	ADJ
cblr-2960	233	21	partnership	partnership	NOUN
cblr-2960	233	22	like	like	ADP
cblr-2960	233	23	a	a	DET
cblr-2960	233	24	hedge	hedge	NOUN
cblr-2960	233	25	fund	fund	NOUN
cblr-2960	233	26	interest	interest	NOUN
cblr-2960	233	27	must	must	AUX
cblr-2960	233	28	be	be	AUX
cblr-2960	233	29	restricted	restrict	VERB
cblr-2960	233	30	to	to	ADP
cblr-2960	233	31	insurance	insurance	NOUN
cblr-2960	233	32	-	-	PUNCT
cblr-2960	233	33	dedicated	dedicate	VERB
cblr-2960	233	34	funds	fund	NOUN
cblr-2960	233	35	.	.	PUNCT
cblr-2960	234	1	section	section	NOUN
cblr-2960	234	2	1.817	1.817	NUM
cblr-2960	234	3	-	-	SYM
cblr-2960	234	4	5(f)(2)(i	5(f)(2)(i	NUM
cblr-2960	234	5	)	)	PUNCT
cblr-2960	234	6	was	be	AUX
cblr-2960	234	7	unchanged	unchanged	ADJ
cblr-2960	234	8	by	by	ADP
cblr-2960	234	9	the	the	DET
cblr-2960	234	10	removal	removal	NOUN
cblr-2960	234	11	of	of	ADP
cblr-2960	234	12	section	section	NOUN
cblr-2960	234	13	1.817	1.817	NUM
cblr-2960	234	14	-	-	SYM
cblr-2960	234	15	5(f)(2)(ii).74	5(f)(2)(ii).74	NUM
cblr-2960	234	16	look	look	NOUN
cblr-2960	234	17	-	-	PUNCT
cblr-2960	234	18	through	through	ADP
cblr-2960	234	19	treatment	treatment	NOUN
cblr-2960	234	20	is	be	AUX
cblr-2960	234	21	available	available	ADJ
cblr-2960	234	22	for	for	ADP
cblr-2960	234	23	interest	interest	NOUN
cblr-2960	234	24	in	in	ADP
cblr-2960	234	25	a	a	DET
cblr-2960	234	26	nonregistered	nonregistered	ADJ
cblr-2960	234	27	partnership	partnership	NOUN
cblr-2960	234	28	if	if	SCONJ
cblr-2960	234	29	:	:	PUNCT
cblr-2960	234	30	(	(	PUNCT
cblr-2960	234	31	a	a	X
cblr-2960	234	32	)	)	PUNCT
cblr-2960	234	33	all	all	DET
cblr-2960	234	34	the	the	DET
cblr-2960	234	35	beneficial	beneficial	ADJ
cblr-2960	234	36	interests	interest	NOUN
cblr-2960	234	37	in	in	ADP
cblr-2960	234	38	the	the	DET
cblr-2960	234	39	nonregistered	nonregistered	PROPN
cblr-2960	234	40	partnership	partnership	NOUN
cblr-2960	234	41	are	be	AUX
cblr-2960	234	42	held	hold	VERB
cblr-2960	234	43	by	by	ADP
cblr-2960	234	44	one	one	NUM
cblr-2960	234	45	or	or	CCONJ
cblr-2960	234	46	more	more	ADV
cblr-2960	234	47	segregated	segregated	ADJ
cblr-2960	234	48	accounts	account	NOUN
cblr-2960	234	49	of	of	ADP
cblr-2960	234	50	one	one	NUM
cblr-2960	234	51	or	or	CCONJ
cblr-2960	234	52	more	more	ADJ
cblr-2960	234	53	insurance	insurance	NOUN
cblr-2960	234	54	companies	company	NOUN
cblr-2960	234	55	;	;	PUNCT
cblr-2960	234	56	and	and	CCONJ
cblr-2960	234	57	(	(	PUNCT
cblr-2960	234	58	b	b	X
cblr-2960	234	59	)	)	PUNCT
cblr-2960	234	60	public	public	ADJ
cblr-2960	234	61	access	access	NOUN
cblr-2960	234	62	to	to	ADP
cblr-2960	234	63	such	such	ADJ
cblr-2960	234	64	nonregistered	nonregistered	ADJ
cblr-2960	234	65	partnership	partnership	NOUN
cblr-2960	234	66	is	be	AUX
cblr-2960	234	67	available	available	ADJ
cblr-2960	234	68	exclusively	exclusively	ADV
cblr-2960	234	69	though	though	SCONJ
cblr-2960	234	70	the	the	DET
cblr-2960	234	71	purchase	purchase	NOUN
cblr-2960	234	72	of	of	ADP
cblr-2960	234	73	a	a	DET
cblr-2960	234	74	variable	variable	ADJ
cblr-2960	234	75	contract.75	contract.75	NOUN
cblr-2960	234	76	therefore	therefore	ADV
cblr-2960	234	77	,	,	PUNCT
cblr-2960	234	78	hedge	hedge	NOUN
cblr-2960	234	79	fund	fund	NOUN
cblr-2960	234	80	insurance	insurance	NOUN
cblr-2960	234	81	wrappers	wrapper	NOUN
cblr-2960	234	82	continue	continue	VERB
cblr-2960	234	83	to	to	PART
cblr-2960	234	84	be	be	AUX
cblr-2960	234	85	offered	offer	VERB
cblr-2960	234	86	in	in	ADP
cblr-2960	234	87	two	two	NUM
cblr-2960	234	88	forms	form	NOUN
cblr-2960	234	89	:	:	PUNCT
cblr-2960	234	90	(	(	PUNCT
cblr-2960	234	91	1	1	X
cblr-2960	234	92	)	)	PUNCT
cblr-2960	234	93	fund	fund	NOUN
cblr-2960	234	94	of	of	ADP
cblr-2960	234	95	funds	fund	NOUN
cblr-2960	234	96	-	-	PUNCT
cblr-2960	234	97	a	a	DET
cblr-2960	234	98	hedge	hedge	NOUN
cblr-2960	234	99	fund	fund	NOUN
cblr-2960	234	100	available	available	ADJ
cblr-2960	234	101	only	only	ADV
cblr-2960	234	102	to	to	ADP
cblr-2960	234	103	insurance	insurance	NOUN
cblr-2960	234	104	company	company	NOUN
cblr-2960	234	105	investors	investor	NOUN
cblr-2960	234	106	that	that	PRON
cblr-2960	234	107	invest	invest	VERB
cblr-2960	234	108	in	in	ADP
cblr-2960	234	109	other	other	ADJ
cblr-2960	234	110	hedge	hedge	NOUN
cblr-2960	234	111	funds	fund	NOUN
cblr-2960	234	112	and	and	CCONJ
cblr-2960	234	113	(	(	PUNCT
cblr-2960	234	114	2	2	NUM
cblr-2960	234	115	)	)	PUNCT
cblr-2960	234	116	71	71	NUM
cblr-2960	234	117	see	see	VERB
cblr-2960	234	118	i.r.s	i.r.s	NOUN
cblr-2960	234	119	.	.	PUNCT
cblr-2960	235	1	priv	priv	PROPN
cblr-2960	235	2	.	.	PUNCT
cblr-2960	236	1	ltr	ltr	PROPN
cblr-2960	236	2	.	.	PUNCT
cblr-2960	236	3	rul	rul	PROPN
cblr-2960	236	4	.	.	PUNCT
cblr-2960	236	5	2002	2002	NUM
cblr-2960	236	6	-	-	SYM
cblr-2960	236	7	44	44	NUM
cblr-2960	236	8	-	-	PUNCT
cblr-2960	236	9	001	001	NUM
cblr-2960	236	10	,	,	PUNCT
cblr-2960	236	11	supra	supra	PROPN
cblr-2960	236	12	note	note	NOUN
cblr-2960	236	13	66	66	NUM
cblr-2960	236	14	;	;	PUNCT
cblr-2960	236	15	internal	internal	ADJ
cblr-2960	236	16	revenue	revenue	NOUN
cblr-2960	236	17	serv	serv	X
cblr-2960	236	18	.	.	PUNCT
cblr-2960	236	19	,	,	PUNCT
cblr-2960	236	20	regs	regs	PROPN
cblr-2960	236	21	target	target	NOUN
cblr-2960	236	22	use	use	NOUN
cblr-2960	236	23	of	of	ADP
cblr-2960	236	24	annuity	annuity	NOUN
cblr-2960	236	25	contracts	contract	NOUN
cblr-2960	236	26	,	,	PUNCT
cblr-2960	236	27	life	life	NOUN
cblr-2960	236	28	insurance	insurance	NOUN
cblr-2960	236	29	as	as	ADP
cblr-2960	236	30	tax	tax	NOUN
cblr-2960	236	31	avoidance	avoidance	NOUN
cblr-2960	236	32	vehicles	vehicle	NOUN
cblr-2960	236	33	,	,	PUNCT
cblr-2960	236	34	2003	2003	NUM
cblr-2960	236	35	tax	tax	NOUN
cblr-2960	236	36	notes	note	VERB
cblr-2960	236	37	146	146	NUM
cblr-2960	236	38	-	-	SYM
cblr-2960	236	39	11	11	NUM
cblr-2960	236	40	(	(	PUNCT
cblr-2960	236	41	2003	2003	NUM
cblr-2960	236	42	)	)	PUNCT
cblr-2960	236	43	(	(	PUNCT
cblr-2960	236	44	"	"	PUNCT
cblr-2960	236	45	the	the	DET
cblr-2960	236	46	proposed	propose	VERB
cblr-2960	236	47	regs	reg	NOUN
cblr-2960	236	48	,	,	PUNCT
cblr-2960	236	49	effective	effective	ADJ
cblr-2960	236	50	on	on	ADP
cblr-2960	236	51	publication	publication	NOUN
cblr-2960	236	52	of	of	ADP
cblr-2960	236	53	the	the	DET
cblr-2960	236	54	final	final	ADJ
cblr-2960	236	55	regs	reg	NOUN
cblr-2960	236	56	,	,	PUNCT
cblr-2960	236	57	would	would	AUX
cblr-2960	236	58	revoke	revoke	VERB
cblr-2960	236	59	reg	reg	NOUN
cblr-2960	236	60	.	.	PUNCT
cblr-2960	237	1	section	section	NOUN
cblr-2960	237	2	1.817	1.817	NUM
cblr-2960	237	3	-	-	SYM
cblr-2960	237	4	5(f)(2)(ii	5(f)(2)(ii	NUM
cblr-2960	237	5	)	)	PUNCT
cblr-2960	237	6	.	.	PUNCT
cblr-2960	238	1	"	"	PUNCT
cblr-2960	238	2	)	)	PUNCT
cblr-2960	238	3	.	.	PUNCT
cblr-2960	239	1	72	72	NUM
cblr-2960	239	2	internal	internal	ADJ
cblr-2960	239	3	revenue	revenue	NOUN
cblr-2960	239	4	serv	serv	X
cblr-2960	239	5	.	.	PUNCT
cblr-2960	239	6	,	,	PUNCT
cblr-2960	239	7	supra	supra	PROPN
cblr-2960	239	8	note	note	NOUN
cblr-2960	239	9	71	71	NUM
cblr-2960	239	10	.	.	PUNCT
cblr-2960	240	1	73	73	NUM
cblr-2960	241	1	i	i	PRON
cblr-2960	241	2	d.	d.	PROPN
cblr-2960	241	3	(	(	PUNCT
cblr-2960	241	4	explaining	explain	VERB
cblr-2960	241	5	that	that	SCONJ
cblr-2960	241	6	congress	congress	PROPN
cblr-2960	241	7	intended	intend	VERB
cblr-2960	241	8	to	to	PART
cblr-2960	241	9	treat	treat	VERB
cblr-2960	241	10	subject	subject	ADJ
cblr-2960	241	11	contracts	contract	NOUN
cblr-2960	241	12	invested	invest	VERB
cblr-2960	241	13	in	in	ADP
cblr-2960	241	14	nonregistered	nonregistered	ADJ
cblr-2960	241	15	partnerships	partnership	NOUN
cblr-2960	241	16	to	to	ADP
cblr-2960	241	17	the	the	DET
cblr-2960	241	18	insurance	insurance	NOUN
cblr-2960	241	19	-	-	PUNCT
cblr-2960	241	20	dedicated	dedicate	VERB
cblr-2960	241	21	limitation	limitation	NOUN
cblr-2960	241	22	)	)	PUNCT
cblr-2960	241	23	.	.	PUNCT
cblr-2960	242	1	71	71	NUM
cblr-2960	243	1	i	i	PRON
cblr-2960	243	2	d.	d.	PROPN
cblr-2960	243	3	(	(	PUNCT
cblr-2960	243	4	allowing	allow	VERB
cblr-2960	243	5	access	access	NOUN
cblr-2960	243	6	only	only	ADV
cblr-2960	243	7	to	to	ADP
cblr-2960	243	8	nonregistered	nonregistered	ADJ
cblr-2960	243	9	partnerships	partnership	NOUN
cblr-2960	243	10	that	that	PRON
cblr-2960	243	11	are	be	AUX
cblr-2960	243	12	not	not	PART
cblr-2960	243	13	available	available	ADJ
cblr-2960	243	14	to	to	ADP
cblr-2960	243	15	the	the	DET
cblr-2960	243	16	general	general	ADJ
cblr-2960	243	17	public	public	NOUN
cblr-2960	243	18	)	)	PUNCT
cblr-2960	243	19	.	.	PUNCT
cblr-2960	244	1	7	7	NUM
cblr-2960	244	2	'	'	PART
cblr-2960	244	3	treas	trea	NOUN
cblr-2960	244	4	.	.	PUNCT
cblr-2960	245	1	reg	reg	PROPN
cblr-2960	245	2	.	.	PUNCT
cblr-2960	246	1	§	§	PROPN
cblr-2960	246	2	1.817	1.817	NUM
cblr-2960	246	3	-	-	SYM
cblr-2960	246	4	5(f)(2)(i	5(f)(2)(i	NUM
cblr-2960	246	5	)	)	PUNCT
cblr-2960	246	6	.	.	PUNCT
cblr-2960	247	1	no	no	INTJ
cblr-2960	247	2	.	.	PUNCT
cblr-2960	248	1	2:6941	2:6941	NUM
cblr-2960	248	2	clone	clone	NOUN
cblr-2960	248	3	of	of	ADP
cblr-2960	248	4	funds	fund	NOUN
cblr-2960	248	5	-	-	PUNCT
cblr-2960	248	6	a	a	DET
cblr-2960	248	7	hedge	hedge	NOUN
cblr-2960	248	8	fund	fund	NOUN
cblr-2960	248	9	offered	offer	VERB
cblr-2960	248	10	only	only	ADV
cblr-2960	248	11	to	to	ADP
cblr-2960	248	12	insurance	insurance	NOUN
cblr-2960	248	13	companies	company	NOUN
cblr-2960	248	14	with	with	ADP
cblr-2960	248	15	investment	investment	NOUN
cblr-2960	248	16	objectives	objective	NOUN
cblr-2960	248	17	and	and	CCONJ
cblr-2960	248	18	strategies	strategy	NOUN
cblr-2960	248	19	that	that	PRON
cblr-2960	248	20	mimic	mimic	VERB
cblr-2960	248	21	those	those	PRON
cblr-2960	248	22	of	of	ADP
cblr-2960	248	23	a	a	DET
cblr-2960	248	24	hedge	hedge	NOUN
cblr-2960	248	25	fund	fund	NOUN
cblr-2960	248	26	managed	manage	VERB
cblr-2960	248	27	by	by	ADP
cblr-2960	248	28	the	the	DET
cblr-2960	248	29	same	same	ADJ
cblr-2960	248	30	portfolio	portfolio	NOUN
cblr-2960	248	31	manager	manager	NOUN
cblr-2960	248	32	and	and	CCONJ
cblr-2960	248	33	available	available	ADJ
cblr-2960	248	34	to	to	ADP
cblr-2960	248	35	eligible	eligible	ADJ
cblr-2960	248	36	investors.7	investors.7	NOUN
cblr-2960	248	37	6	6	NUM
cblr-2960	248	38	iv	iv	NOUN
cblr-2960	248	39	.	.	PUNCT
cblr-2960	249	1	methods	method	NOUN
cblr-2960	249	2	of	of	ADP
cblr-2960	249	3	analysis	analysis	NOUN
cblr-2960	249	4	the	the	DET
cblr-2960	249	5	efficiency	efficiency	NOUN
cblr-2960	249	6	of	of	ADP
cblr-2960	249	7	reform	reform	NOUN
cblr-2960	249	8	measures	measure	NOUN
cblr-2960	249	9	in	in	ADP
cblr-2960	249	10	addressing	address	VERB
cblr-2960	249	11	tax	tax	NOUN
cblr-2960	249	12	avoidance	avoidance	NOUN
cblr-2960	249	13	mechanisms	mechanism	NOUN
cblr-2960	249	14	can	can	AUX
cblr-2960	249	15	be	be	AUX
cblr-2960	249	16	analyzed	analyze	VERB
cblr-2960	249	17	by	by	ADP
cblr-2960	249	18	examining	examine	VERB
cblr-2960	249	19	the	the	DET
cblr-2960	249	20	change	change	NOUN
cblr-2960	249	21	in	in	ADP
cblr-2960	249	22	taxpayer	taxpayer	NOUN
cblr-2960	249	23	behavior	behavior	NOUN
cblr-2960	249	24	and	and	CCONJ
cblr-2960	249	25	the	the	DET
cblr-2960	249	26	consequent	consequent	ADJ
cblr-2960	249	27	change	change	NOUN
cblr-2960	249	28	in	in	ADP
cblr-2960	249	29	revenue	revenue	NOUN
cblr-2960	249	30	.	.	PUNCT
cblr-2960	250	1	the	the	DET
cblr-2960	250	2	primary	primary	ADJ
cblr-2960	250	3	purpose	purpose	NOUN
cblr-2960	250	4	of	of	ADP
cblr-2960	250	5	anti	anti	ADJ
cblr-2960	250	6	-	-	ADJ
cblr-2960	250	7	avoidance	avoidance	ADJ
cblr-2960	250	8	doctrines	doctrine	NOUN
cblr-2960	250	9	is	be	AUX
cblr-2960	250	10	to	to	PART
cblr-2960	250	11	prevent	prevent	VERB
cblr-2960	250	12	taxpayers	taxpayer	NOUN
cblr-2960	250	13	from	from	ADP
cblr-2960	250	14	shifting	shift	VERB
cblr-2960	250	15	their	their	PRON
cblr-2960	250	16	activity	activity	NOUN
cblr-2960	250	17	into	into	ADP
cblr-2960	250	18	other	other	ADJ
cblr-2960	250	19	tax	tax	NOUN
cblr-2960	250	20	shelters.77	shelters.77	VERB
cblr-2960	250	21	by	by	ADP
cblr-2960	250	22	preventing	prevent	VERB
cblr-2960	250	23	taxpayers	taxpayer	NOUN
cblr-2960	250	24	from	from	ADP
cblr-2960	250	25	engaging	engage	VERB
cblr-2960	250	26	in	in	ADP
cblr-2960	250	27	the	the	DET
cblr-2960	250	28	same	same	ADJ
cblr-2960	250	29	tax	tax	NOUN
cblr-2960	250	30	shelter	shelter	NOUN
cblr-2960	250	31	or	or	CCONJ
cblr-2960	250	32	shifting	shift	VERB
cblr-2960	250	33	into	into	ADP
cblr-2960	250	34	other	other	ADJ
cblr-2960	250	35	shelters	shelter	NOUN
cblr-2960	250	36	,	,	PUNCT
cblr-2960	250	37	the	the	DET
cblr-2960	250	38	irs	irs	PROPN
cblr-2960	250	39	is	be	AUX
cblr-2960	250	40	able	able	ADJ
cblr-2960	250	41	to	to	PART
cblr-2960	250	42	capture	capture	VERB
cblr-2960	250	43	additional	additional	ADJ
cblr-2960	250	44	revenue	revenue	NOUN
cblr-2960	250	45	.	.	PUNCT
cblr-2960	250	46	8	8	NUM
cblr-2960	250	47	in	in	ADP
cblr-2960	250	48	some	some	DET
cblr-2960	250	49	cases	case	NOUN
cblr-2960	250	50	,	,	PUNCT
cblr-2960	250	51	however	however	ADV
cblr-2960	250	52	,	,	PUNCT
cblr-2960	250	53	taxpayers	taxpayer	NOUN
cblr-2960	250	54	tweak	tweak	VERB
cblr-2960	250	55	the	the	DET
cblr-2960	250	56	deal	deal	NOUN
cblr-2960	250	57	just	just	ADV
cblr-2960	250	58	enough	enough	ADV
cblr-2960	250	59	to	to	PART
cblr-2960	250	60	sidestep	sidestep	VERB
cblr-2960	250	61	the	the	DET
cblr-2960	250	62	reform.79	reform.79	NOUN
cblr-2960	250	63	these	these	DET
cblr-2960	250	64	avoidable	avoidable	ADJ
cblr-2960	250	65	measures	measure	NOUN
cblr-2960	250	66	do	do	AUX
cblr-2960	250	67	not	not	PART
cblr-2960	250	68	raise	raise	VERB
cblr-2960	250	69	revenue	revenue	NOUN
cblr-2960	250	70	or	or	CCONJ
cblr-2960	250	71	increase	increase	VERB
cblr-2960	250	72	the	the	DET
cblr-2960	250	73	tax	tax	NOUN
cblr-2960	250	74	burden	burden	NOUN
cblr-2960	250	75	on	on	ADP
cblr-2960	250	76	sophisticated	sophisticated	ADJ
cblr-2960	250	77	and	and	CCONJ
cblr-2960	250	78	wealthy	wealthy	ADJ
cblr-2960	250	79	taxpayers.8	taxpayers.8	PROPN
cblr-2960	250	80	'	'	PUNCT
cblr-2960	250	81	thus	thus	ADV
cblr-2960	250	82	,	,	PUNCT
cblr-2960	250	83	anti	anti	ADJ
cblr-2960	250	84	-	-	ADJ
cblr-2960	250	85	avoidance	avoidance	ADJ
cblr-2960	250	86	doctrines	doctrine	NOUN
cblr-2960	250	87	that	that	PRON
cblr-2960	250	88	merely	merely	ADV
cblr-2960	250	89	induce	induce	VERB
cblr-2960	250	90	taxpayers	taxpayer	NOUN
cblr-2960	250	91	to	to	PART
cblr-2960	250	92	shift	shift	VERB
cblr-2960	250	93	their	their	PRON
cblr-2960	250	94	behavior	behavior	NOUN
cblr-2960	250	95	toward	toward	ADP
cblr-2960	250	96	worse	bad	ADJ
cblr-2960	250	97	shelters	shelter	NOUN
cblr-2960	250	98	without	without	ADP
cblr-2960	250	99	raising	raise	VERB
cblr-2960	250	100	significant	significant	ADJ
cblr-2960	250	101	revenue	revenue	NOUN
cblr-2960	250	102	are	be	AUX
cblr-2960	250	103	inefficient	inefficient	ADJ
cblr-2960	250	104	.	.	PUNCT
cblr-2960	251	1	81	81	NUM
cblr-2960	251	2	in	in	ADP
cblr-2960	251	3	contrast	contrast	NOUN
cblr-2960	251	4	,	,	PUNCT
cblr-2960	251	5	anti	anti	ADJ
cblr-2960	251	6	-	-	ADJ
cblr-2960	251	7	avoidance	avoidance	ADJ
cblr-2960	251	8	doctrines	doctrine	NOUN
cblr-2960	251	9	that	that	PRON
cblr-2960	251	10	cause	cause	VERB
cblr-2960	251	11	taxpayers	taxpayer	NOUN
cblr-2960	251	12	to	to	PART
cblr-2960	251	13	return	return	VERB
cblr-2960	251	14	to	to	ADP
cblr-2960	251	15	non	non	ADJ
cblr-2960	251	16	-	-	ADJ
cblr-2960	251	17	avoidance	avoidance	ADJ
cblr-2960	251	18	behavior	behavior	NOUN
cblr-2960	251	19	and	and	CCONJ
cblr-2960	251	20	,	,	PUNCT
cblr-2960	251	21	therefore	therefore	ADV
cblr-2960	251	22	,	,	PUNCT
cblr-2960	251	23	raise	raise	VERB
cblr-2960	251	24	significant	significant	ADJ
cblr-2960	251	25	revenue	revenue	NOUN
cblr-2960	251	26	,	,	PUNCT
cblr-2960	251	27	are	be	AUX
cblr-2960	251	28	more	more	ADV
cblr-2960	251	29	efficient.82	efficient.82	ADJ
cblr-2960	251	30	therefore	therefore	ADV
cblr-2960	251	31	,	,	PUNCT
cblr-2960	251	32	successful	successful	ADJ
cblr-2960	251	33	anti	anti	ADJ
cblr-2960	251	34	-	-	ADJ
cblr-2960	251	35	avoidance	avoidance	ADJ
cblr-2960	251	36	reforms	reform	NOUN
cblr-2960	251	37	will	will	AUX
cblr-2960	251	38	decrease	decrease	VERB
cblr-2960	251	39	the	the	DET
cblr-2960	251	40	76	76	NUM
cblr-2960	251	41	see	see	VERB
cblr-2960	251	42	needham	needham	PROPN
cblr-2960	251	43	&	&	CCONJ
cblr-2960	251	44	brause	brause	PROPN
cblr-2960	251	45	,	,	PUNCT
cblr-2960	251	46	supra	supra	PROPN
cblr-2960	251	47	note	note	PROPN
cblr-2960	251	48	53	53	NUM
cblr-2960	251	49	,	,	PUNCT
cblr-2960	251	50	at	at	ADP
cblr-2960	251	51	a-100	a-100	PROPN
cblr-2960	251	52	.	.	PUNCT
cblr-2960	251	53	"	"	PUNCT
cblr-2960	252	1	see	see	VERB
cblr-2960	252	2	weisbach	weisbach	NOUN
cblr-2960	252	3	,	,	PUNCT
cblr-2960	252	4	supra	supra	ADJ
cblr-2960	252	5	note	note	NOUN
cblr-2960	252	6	8	8	NUM
cblr-2960	252	7	,	,	PUNCT
cblr-2960	252	8	at	at	ADP
cblr-2960	252	9	99	99	NUM
cblr-2960	252	10	(	(	PUNCT
cblr-2960	252	11	arguing	argue	VERB
cblr-2960	252	12	that	that	SCONJ
cblr-2960	252	13	,	,	PUNCT
cblr-2960	252	14	by	by	ADP
cblr-2960	252	15	limiting	limit	VERB
cblr-2960	252	16	tax	tax	NOUN
cblr-2960	252	17	shelters	shelter	NOUN
cblr-2960	252	18	,	,	PUNCT
cblr-2960	252	19	"	"	PUNCT
cblr-2960	252	20	the	the	DET
cblr-2960	252	21	hope	hope	NOUN
cblr-2960	253	1	[	[	X
cblr-2960	253	2	is	be	AUX
cblr-2960	253	3	]	]	PUNCT
cblr-2960	253	4	that	that	SCONJ
cblr-2960	253	5	decisions	decision	NOUN
cblr-2960	253	6	will	will	AUX
cblr-2960	253	7	be	be	AUX
cblr-2960	253	8	based	base	VERB
cblr-2960	253	9	less	less	ADV
cblr-2960	253	10	on	on	ADP
cblr-2960	253	11	taxes	taxis	NOUN
cblr-2960	253	12	and	and	CCONJ
cblr-2960	253	13	more	more	ADJ
cblr-2960	253	14	on	on	ADP
cblr-2960	253	15	other	other	ADJ
cblr-2960	253	16	considerations	consideration	NOUN
cblr-2960	253	17	,	,	PUNCT
cblr-2960	253	18	"	"	PUNCT
cblr-2960	253	19	such	such	ADJ
cblr-2960	253	20	as	as	ADP
cblr-2960	253	21	a	a	DET
cblr-2960	253	22	business	business	NOUN
cblr-2960	253	23	purpose	purpose	NOUN
cblr-2960	253	24	or	or	CCONJ
cblr-2960	253	25	non	non	ADJ
cblr-2960	253	26	-	-	ADJ
cblr-2960	253	27	tax	tax	ADJ
cblr-2960	253	28	economics	economic	NOUN
cblr-2960	253	29	)	)	PUNCT
cblr-2960	253	30	.	.	PUNCT
cblr-2960	254	1	78	78	NUM
cblr-2960	254	2	see	see	VERB
cblr-2960	254	3	i	i	PRON
cblr-2960	254	4	d.	d.	PROPN
cblr-2960	254	5	at	at	ADP
cblr-2960	254	6	102	102	NUM
cblr-2960	254	7	-	-	SYM
cblr-2960	254	8	03	03	NUM
cblr-2960	254	9	(	(	PUNCT
cblr-2960	254	10	"	"	PUNCT
cblr-2960	254	11	if	if	SCONJ
cblr-2960	254	12	taxpayers	taxpayer	NOUN
cblr-2960	254	13	can	can	AUX
cblr-2960	254	14	easily	easily	ADV
cblr-2960	254	15	restructure	restructure	VERB
cblr-2960	254	16	transactions	transaction	NOUN
cblr-2960	254	17	to	to	PART
cblr-2960	254	18	avoid	avoid	VERB
cblr-2960	254	19	the	the	DET
cblr-2960	254	20	anti	anti	ADJ
cblr-2960	254	21	-	-	ADJ
cblr-2960	254	22	avoidance	avoidance	ADJ
cblr-2960	254	23	doctrines	doctrine	NOUN
cblr-2960	254	24	,	,	PUNCT
cblr-2960	254	25	there	there	PRON
cblr-2960	254	26	will	will	AUX
cblr-2960	254	27	be	be	AUX
cblr-2960	254	28	.	.	PUNCT
cblr-2960	254	29	.	.	PUNCT
cblr-2960	255	1	.little	.little	PUNCT
cblr-2960	256	1	change	change	VERB
cblr-2960	256	2	in	in	ADP
cblr-2960	256	3	revenue	revenue	NOUN
cblr-2960	256	4	.	.	PUNCT
cblr-2960	257	1	if	if	SCONJ
cblr-2960	257	2	,	,	PUNCT
cblr-2960	257	3	on	on	ADP
cblr-2960	257	4	the	the	DET
cblr-2960	257	5	other	other	ADJ
cblr-2960	257	6	hand	hand	NOUN
cblr-2960	257	7	,	,	PUNCT
cblr-2960	257	8	a	a	DET
cblr-2960	257	9	taxpayer	taxpayer	NOUN
cblr-2960	257	10	can	can	AUX
cblr-2960	257	11	not	not	PART
cblr-2960	257	12	readily	readily	ADV
cblr-2960	257	13	avoid	avoid	VERB
cblr-2960	257	14	the	the	DET
cblr-2960	257	15	antiavoidance	antiavoidance	NOUN
cblr-2960	257	16	doctrines	doctrine	NOUN
cblr-2960	257	17	,	,	PUNCT
cblr-2960	257	18	there	there	PRON
cblr-2960	257	19	will	will	AUX
cblr-2960	257	20	be	be	AUX
cblr-2960	257	21	a	a	DET
cblr-2960	257	22	larger	large	ADJ
cblr-2960	257	23	effect	effect	NOUN
cblr-2960	257	24	on	on	ADP
cblr-2960	257	25	revenue	revenue	NOUN
cblr-2960	257	26	.	.	PUNCT
cblr-2960	257	27	"	"	PUNCT
cblr-2960	257	28	)	)	PUNCT
cblr-2960	257	29	.	.	PUNCT
cblr-2960	258	1	"	"	PUNCT
cblr-2960	258	2	see	see	VERB
cblr-2960	258	3	schizer	schizer	NOUN
cblr-2960	258	4	,	,	PUNCT
cblr-2960	258	5	supra	supra	PROPN
cblr-2960	258	6	note	note	NOUN
cblr-2960	258	7	20	20	NUM
cblr-2960	258	8	,	,	PUNCT
cblr-2960	258	9	at	at	ADP
cblr-2960	258	10	1315	1315	NUM
cblr-2960	258	11	.	.	PUNCT
cblr-2960	259	1	80	80	NUM
cblr-2960	260	1	i	i	PROPN
cblr-2960	260	2	d.	d.	PROPN
cblr-2960	260	3	"	"	PUNCT
cblr-2960	260	4	see	see	VERB
cblr-2960	260	5	weisbach	weisbach	NOUN
cblr-2960	260	6	,	,	PUNCT
cblr-2960	260	7	supra	supra	ADJ
cblr-2960	260	8	note	note	NOUN
cblr-2960	260	9	8	8	NUM
cblr-2960	260	10	,	,	PUNCT
cblr-2960	260	11	at	at	ADP
cblr-2960	260	12	103	103	NUM
cblr-2960	260	13	(	(	PUNCT
cblr-2960	260	14	explaining	explain	VERB
cblr-2960	260	15	that	that	SCONJ
cblr-2960	260	16	failing	fail	VERB
cblr-2960	260	17	to	to	PART
cblr-2960	260	18	cause	cause	VERB
cblr-2960	260	19	taxpayers	taxpayer	NOUN
cblr-2960	260	20	to	to	PART
cblr-2960	260	21	shift	shift	VERB
cblr-2960	260	22	toward	toward	ADP
cblr-2960	260	23	non	non	ADJ
cblr-2960	260	24	-	-	ADJ
cblr-2960	260	25	avoidance	avoidance	ADJ
cblr-2960	260	26	behavior	behavior	NOUN
cblr-2960	260	27	will	will	AUX
cblr-2960	260	28	generate	generate	VERB
cblr-2960	260	29	insignificant	insignificant	ADJ
cblr-2960	260	30	revenue	revenue	NOUN
cblr-2960	260	31	)	)	PUNCT
cblr-2960	260	32	.	.	PUNCT
cblr-2960	261	1	82	82	NUM
cblr-2960	261	2	see	see	VERB
cblr-2960	261	3	i	i	PRON
cblr-2960	261	4	d.	d.	PROPN
cblr-2960	262	1	[	[	X
cblr-2960	262	2	vol	vol	NOUN
cblr-2960	262	3	.	.	PUNCT
cblr-2960	263	1	2008col	2008col	NUM
cblr-2960	263	2	umia	umia	NOUN
cblr-2960	263	3	b	b	PROPN
cblr-2960	263	4	usiness	usiness	NOUN
cblr-2960	263	5	la	la	PROPN
cblr-2960	263	6	w	w	PROPN
cblr-2960	263	7	re	re	PROPN
cblr-2960	263	8	vie	vie	PROPN
cblr-2960	263	9	w	w	PROPN
cblr-2960	263	10	job	job	NOUN
cblr-2960	263	11	well	well	ADV
cblr-2960	263	12	done	do	VERB
cblr-2960	263	13	taxpayer	taxpayer	NOUN
cblr-2960	263	14	's	's	PART
cblr-2960	263	15	elasticity	elasticity	NOUN
cblr-2960	263	16	of	of	ADP
cblr-2960	263	17	taxable	taxable	ADJ
cblr-2960	263	18	income	income	NOUN
cblr-2960	263	19	,	,	PUNCT
cblr-2960	263	20	limit	limit	VERB
cblr-2960	263	21	the	the	DET
cblr-2960	263	22	distortionary	distortionary	ADJ
cblr-2960	263	23	effect	effect	NOUN
cblr-2960	263	24	,	,	PUNCT
cblr-2960	263	25	and	and	CCONJ
cblr-2960	263	26	produce	produce	VERB
cblr-2960	263	27	effective	effective	ADJ
cblr-2960	263	28	frictions	friction	NOUN
cblr-2960	263	29	that	that	PRON
cblr-2960	263	30	constrain	constrain	VERB
cblr-2960	263	31	tax	tax	NOUN
cblr-2960	263	32	planning	planning	NOUN
cblr-2960	263	33	.	.	PUNCT
cblr-2960	264	1	a.	a.	NOUN
cblr-2960	264	2	elasticity	elasticity	NOUN
cblr-2960	264	3	of	of	ADP
cblr-2960	264	4	taxable	taxable	ADJ
cblr-2960	264	5	income	income	NOUN
cblr-2960	264	6	and	and	CCONJ
cblr-2960	264	7	the	the	DET
cblr-2960	264	8	distortionary	distortionary	ADJ
cblr-2960	264	9	effect	effect	NOUN
cblr-2960	264	10	anti	anti	ADJ
cblr-2960	264	11	-	-	ADJ
cblr-2960	264	12	avoidance	avoidance	ADJ
cblr-2960	264	13	doctrines	doctrine	NOUN
cblr-2960	264	14	affect	affect	VERB
cblr-2960	264	15	the	the	DET
cblr-2960	264	16	ability	ability	NOUN
cblr-2960	264	17	of	of	ADP
cblr-2960	264	18	taxpayers	taxpayer	NOUN
cblr-2960	264	19	to	to	PART
cblr-2960	264	20	shift	shift	VERB
cblr-2960	264	21	into	into	ADP
cblr-2960	264	22	shelters	shelter	NOUN
cblr-2960	264	23	and	and	CCONJ
cblr-2960	264	24	,	,	PUNCT
cblr-2960	264	25	therefore	therefore	ADV
cblr-2960	264	26	,	,	PUNCT
cblr-2960	264	27	are	be	AUX
cblr-2960	264	28	a	a	DET
cblr-2960	264	29	policy	policy	NOUN
cblr-2960	264	30	tool	tool	NOUN
cblr-2960	264	31	that	that	PRON
cblr-2960	264	32	affects	affect	VERB
cblr-2960	264	33	the	the	DET
cblr-2960	264	34	elasticity	elasticity	NOUN
cblr-2960	264	35	of	of	ADP
cblr-2960	264	36	taxable	taxable	ADJ
cblr-2960	264	37	income	income	NOUN
cblr-2960	264	38	and	and	CCONJ
cblr-2960	264	39	the	the	DET
cblr-2960	264	40	efficiency	efficiency	NOUN
cblr-2960	264	41	of	of	ADP
cblr-2960	264	42	the	the	DET
cblr-2960	264	43	tax	tax	NOUN
cblr-2960	264	44	system.3	system.3	NOUN
cblr-2960	264	45	the	the	DET
cblr-2960	264	46	goal	goal	NOUN
cblr-2960	264	47	of	of	ADP
cblr-2960	264	48	efficient	efficient	ADJ
cblr-2960	264	49	tax	tax	NOUN
cblr-2960	264	50	reform	reform	NOUN
cblr-2960	264	51	is	be	AUX
cblr-2960	264	52	to	to	PART
cblr-2960	264	53	enforce	enforce	VERB
cblr-2960	264	54	antiavoidance	antiavoidance	NOUN
cblr-2960	264	55	doctrines	doctrine	NOUN
cblr-2960	264	56	at	at	ADP
cblr-2960	264	57	an	an	DET
cblr-2960	264	58	optimal	optimal	ADJ
cblr-2960	264	59	level	level	NOUN
cblr-2960	264	60	,	,	PUNCT
cblr-2960	264	61	reducing	reduce	VERB
cblr-2960	264	62	the	the	DET
cblr-2960	264	63	taxpayer	taxpayer	NOUN
cblr-2960	264	64	's	's	PART
cblr-2960	264	65	elasticity	elasticity	NOUN
cblr-2960	264	66	of	of	ADP
cblr-2960	264	67	taxable	taxable	ADJ
cblr-2960	264	68	income	income	NOUN
cblr-2960	264	69	,	,	PUNCT
cblr-2960	264	70	while	while	SCONJ
cblr-2960	264	71	at	at	ADP
cblr-2960	264	72	the	the	DET
cblr-2960	264	73	same	same	ADJ
cblr-2960	264	74	time	time	NOUN
cblr-2960	264	75	limiting	limit	VERB
cblr-2960	264	76	the	the	DET
cblr-2960	264	77	distortionary	distortionary	ADJ
cblr-2960	264	78	effect.84	effect.84	ADP
cblr-2960	264	79	the	the	DET
cblr-2960	264	80	elasticity	elasticity	NOUN
cblr-2960	264	81	of	of	ADP
cblr-2960	264	82	taxable	taxable	ADJ
cblr-2960	264	83	income	income	NOUN
cblr-2960	264	84	defines	define	VERB
cblr-2960	264	85	the	the	DET
cblr-2960	264	86	ability	ability	NOUN
cblr-2960	264	87	or	or	CCONJ
cblr-2960	264	88	relative	relative	ADJ
cblr-2960	264	89	inability	inability	NOUN
cblr-2960	264	90	of	of	ADP
cblr-2960	264	91	taxpayers	taxpayer	NOUN
cblr-2960	264	92	to	to	PART
cblr-2960	264	93	shift	shift	VERB
cblr-2960	264	94	their	their	PRON
cblr-2960	264	95	activities	activity	NOUN
cblr-2960	264	96	into	into	ADP
cblr-2960	264	97	other	other	ADJ
cblr-2960	264	98	tax	tax	NOUN
cblr-2960	264	99	shelters	shelter	NOUN
cblr-2960	264	100	.	.	PUNCT
cblr-2960	265	1	5	5	NUM
cblr-2960	265	2	stronger	strong	ADJ
cblr-2960	265	3	anti	anti	ADJ
cblr-2960	265	4	-	-	ADJ
cblr-2960	265	5	avoidance	avoidance	ADJ
cblr-2960	265	6	doctrines	doctrine	NOUN
cblr-2960	265	7	reduce	reduce	VERB
cblr-2960	265	8	the	the	DET
cblr-2960	265	9	elasticity	elasticity	NOUN
cblr-2960	265	10	of	of	ADP
cblr-2960	265	11	taxable	taxable	ADJ
cblr-2960	265	12	income	income	NOUN
cblr-2960	265	13	because	because	SCONJ
cblr-2960	265	14	they	they	PRON
cblr-2960	265	15	make	make	VERB
cblr-2960	265	16	it	it	PRON
cblr-2960	265	17	more	more	ADV
cblr-2960	265	18	difficult	difficult	ADJ
cblr-2960	265	19	to	to	PART
cblr-2960	265	20	shift	shift	VERB
cblr-2960	265	21	into	into	ADP
cblr-2960	265	22	shelters.8	shelters.8	PROPN
cblr-2960	265	23	6	6	NUM
cblr-2960	265	24	the	the	DET
cblr-2960	265	25	distortionary	distortionary	ADJ
cblr-2960	265	26	effect	effect	NOUN
cblr-2960	265	27	occurs	occur	VERB
cblr-2960	265	28	when	when	SCONJ
cblr-2960	265	29	taxpayers	taxpayer	NOUN
cblr-2960	265	30	respond	respond	VERB
cblr-2960	265	31	to	to	ADP
cblr-2960	265	32	an	an	DET
cblr-2960	265	33	anti	anti	ADJ
cblr-2960	265	34	-	-	ADJ
cblr-2960	265	35	avoidance	avoidance	ADJ
cblr-2960	265	36	doctrine	doctrine	NOUN
cblr-2960	265	37	by	by	ADP
cblr-2960	265	38	wasting	waste	VERB
cblr-2960	265	39	more	more	ADJ
cblr-2960	265	40	resources	resource	NOUN
cblr-2960	265	41	through	through	ADP
cblr-2960	265	42	engaging	engage	VERB
cblr-2960	265	43	in	in	ADP
cblr-2960	265	44	more	more	ADV
cblr-2960	265	45	costly	costly	ADJ
cblr-2960	265	46	shelters	shelter	NOUN
cblr-2960	265	47	.	.	PUNCT
cblr-2960	266	1	7	7	NUM
cblr-2960	266	2	83	83	NUM
cblr-2960	266	3	see	see	VERB
cblr-2960	266	4	i	i	PRON
cblr-2960	266	5	d.	d.	PROPN
cblr-2960	266	6	at	at	ADP
cblr-2960	266	7	93	93	NUM
cblr-2960	266	8	.	.	PUNCT
cblr-2960	267	1	84	84	NUM
cblr-2960	268	1	i	i	PRON
cblr-2960	268	2	d.	d.	NOUN
cblr-2960	268	3	5	5	NUM
cblr-2960	268	4	weisbach	weisbach	NOUN
cblr-2960	268	5	gives	give	VERB
cblr-2960	268	6	an	an	DET
cblr-2960	268	7	example	example	NOUN
cblr-2960	268	8	of	of	ADP
cblr-2960	268	9	two	two	NUM
cblr-2960	268	10	commodities	commodity	NOUN
cblr-2960	268	11	that	that	PRON
cblr-2960	268	12	can	can	AUX
cblr-2960	268	13	be	be	AUX
cblr-2960	268	14	consumed	consume	VERB
cblr-2960	268	15	,	,	PUNCT
cblr-2960	268	16	apples	apple	NOUN
cblr-2960	268	17	and	and	CCONJ
cblr-2960	268	18	pears	pear	NOUN
cblr-2960	268	19	:	:	PUNCT
cblr-2960	268	20	"	"	PUNCT
cblr-2960	268	21	[	[	X
cblr-2960	268	22	sluppose	sluppose	VERB
cblr-2960	268	23	that	that	SCONJ
cblr-2960	268	24	we	we	PRON
cblr-2960	268	25	currently	currently	ADV
cblr-2960	268	26	impose	impose	VERB
cblr-2960	268	27	a	a	DET
cblr-2960	268	28	tax	tax	NOUN
cblr-2960	268	29	just	just	ADV
cblr-2960	268	30	on	on	ADP
cblr-2960	268	31	apples	apple	NOUN
cblr-2960	268	32	.	.	PUNCT
cblr-2960	269	1	the	the	DET
cblr-2960	269	2	individual	individual	NOUN
cblr-2960	269	3	will	will	AUX
cblr-2960	269	4	shift	shift	VERB
cblr-2960	269	5	some	some	PRON
cblr-2960	269	6	of	of	ADP
cblr-2960	269	7	his	his	PRON
cblr-2960	269	8	apple	apple	NOUN
cblr-2960	269	9	consumption	consumption	NOUN
cblr-2960	269	10	to	to	ADP
cblr-2960	269	11	pears	pear	NOUN
cblr-2960	269	12	because	because	SCONJ
cblr-2960	269	13	of	of	ADP
cblr-2960	269	14	the	the	DET
cblr-2960	269	15	tax	tax	NOUN
cblr-2960	269	16	and	and	CCONJ
cblr-2960	269	17	may	may	AUX
cblr-2960	269	18	also	also	ADV
cblr-2960	269	19	reduce	reduce	VERB
cblr-2960	269	20	overall	overall	ADJ
cblr-2960	269	21	consumption	consumption	NOUN
cblr-2960	269	22	.	.	PUNCT
cblr-2960	270	1	these	these	DET
cblr-2960	270	2	shifts	shift	NOUN
cblr-2960	270	3	-	-	PUNCT
cblr-2960	270	4	to	to	ADP
cblr-2960	270	5	pears	pear	NOUN
cblr-2960	270	6	and	and	CCONJ
cblr-2960	270	7	to	to	ADP
cblr-2960	270	8	less	less	ADV
cblr-2960	270	9	consumption	consumption	NOUN
cblr-2960	270	10	-	-	PUNCT
cblr-2960	270	11	create	create	VERB
cblr-2960	270	12	the	the	DET
cblr-2960	270	13	elasticity	elasticity	NOUN
cblr-2960	270	14	of	of	ADP
cblr-2960	270	15	taxable	taxable	ADJ
cblr-2960	270	16	income	income	NOUN
cblr-2960	270	17	.	.	PUNCT
cblr-2960	270	18	.	.	PUNCT
cblr-2960	270	19	.	.	PUNCT
cblr-2960	270	20	.	.	PUNCT
cblr-2960	270	21	"	"	PUNCT
cblr-2960	271	1	i	i	PRON
cblr-2960	271	2	d.	d.	PROPN
cblr-2960	271	3	at	at	ADP
cblr-2960	271	4	97	97	NUM
cblr-2960	271	5	.	.	PUNCT
cblr-2960	272	1	the	the	DET
cblr-2960	272	2	elasticity	elasticity	NOUN
cblr-2960	272	3	of	of	ADP
cblr-2960	272	4	taxable	taxable	ADJ
cblr-2960	272	5	income	income	NOUN
cblr-2960	272	6	measures	measure	NOUN
cblr-2960	272	7	the	the	DET
cblr-2960	272	8	amount	amount	NOUN
cblr-2960	272	9	by	by	ADP
cblr-2960	272	10	which	which	PRON
cblr-2960	272	11	taxable	taxable	ADJ
cblr-2960	272	12	income	income	NOUN
cblr-2960	272	13	changes	change	NOUN
cblr-2960	272	14	when	when	SCONJ
cblr-2960	272	15	the	the	DET
cblr-2960	272	16	tax	tax	NOUN
cblr-2960	272	17	rate	rate	NOUN
cblr-2960	272	18	is	be	AUX
cblr-2960	272	19	increased	increase	VERB
cblr-2960	272	20	.	.	PUNCT
cblr-2960	273	1	i	i	PRON
cblr-2960	273	2	d.	d.	PROPN
cblr-2960	273	3	see	see	VERB
cblr-2960	273	4	weisbach	weisbach	NOUN
cblr-2960	273	5	,	,	PUNCT
cblr-2960	273	6	supra	supra	ADJ
cblr-2960	273	7	note	note	NOUN
cblr-2960	273	8	8	8	NUM
cblr-2960	273	9	,	,	PUNCT
cblr-2960	273	10	at	at	ADP
cblr-2960	273	11	93	93	NUM
cblr-2960	273	12	.	.	PUNCT
cblr-2960	274	1	87	87	NUM
cblr-2960	274	2	"	"	PUNCT
cblr-2960	274	3	the	the	DET
cblr-2960	274	4	distortionary	distortionary	ADJ
cblr-2960	274	5	effect	effect	NOUN
cblr-2960	274	6	means	mean	VERB
cblr-2960	274	7	that	that	SCONJ
cblr-2960	274	8	an	an	DET
cblr-2960	274	9	increase	increase	NOUN
cblr-2960	274	10	in	in	ADP
cblr-2960	274	11	the	the	DET
cblr-2960	274	12	strength	strength	NOUN
cblr-2960	274	13	of	of	ADP
cblr-2960	274	14	anti	anti	ADJ
cblr-2960	274	15	-	-	ADJ
cblr-2960	274	16	avoidance	avoidance	ADJ
cblr-2960	274	17	doctrines	doctrine	NOUN
cblr-2960	274	18	makes	make	VERB
cblr-2960	274	19	shelters	shelter	NOUN
cblr-2960	274	20	worse	bad	ADJ
cblr-2960	274	21	.	.	PUNCT
cblr-2960	274	22	"	"	PUNCT
cblr-2960	275	1	i	i	PRON
cblr-2960	275	2	d.	d.	PROPN
cblr-2960	275	3	at	at	ADP
cblr-2960	275	4	100	100	NUM
cblr-2960	275	5	.	.	PUNCT
cblr-2960	276	1	for	for	ADP
cblr-2960	276	2	example	example	NOUN
cblr-2960	276	3	,	,	PUNCT
cblr-2960	276	4	consider	consider	VERB
cblr-2960	276	5	a	a	DET
cblr-2960	276	6	small	small	ADJ
cblr-2960	276	7	increase	increase	NOUN
cblr-2960	276	8	in	in	ADP
cblr-2960	276	9	the	the	DET
cblr-2960	276	10	strength	strength	NOUN
cblr-2960	276	11	of	of	ADP
cblr-2960	276	12	an	an	DET
cblr-2960	276	13	anti	anti	ADJ
cblr-2960	276	14	-	-	ADJ
cblr-2960	276	15	avoidance	avoidance	ADJ
cblr-2960	276	16	doctrine	doctrine	NOUN
cblr-2960	276	17	.	.	PUNCT
cblr-2960	277	1	"	"	PUNCT
cblr-2960	277	2	[	[	X
cblr-2960	277	3	prior	prior	ADV
cblr-2960	277	4	]	]	PUNCT
cblr-2960	277	5	to	to	ADP
cblr-2960	277	6	the	the	DET
cblr-2960	277	7	increase	increase	NOUN
cblr-2960	277	8	,	,	PUNCT
cblr-2960	277	9	taxpayers	taxpayer	NOUN
cblr-2960	277	10	would	would	AUX
cblr-2960	277	11	have	have	AUX
cblr-2960	277	12	entered	enter	VERB
cblr-2960	277	13	into	into	ADP
cblr-2960	277	14	tax	tax	NOUN
cblr-2960	277	15	avoidance	avoidance	NOUN
cblr-2960	277	16	transactions	transaction	NOUN
cblr-2960	277	17	until	until	ADP
cblr-2960	277	18	the	the	DET
cblr-2960	277	19	cost	cost	NOUN
cblr-2960	277	20	of	of	ADP
cblr-2960	277	21	avoidance	avoidance	NOUN
cblr-2960	277	22	exactly	exactly	ADV
cblr-2960	277	23	equaled	equal	VERB
cblr-2960	277	24	the	the	DET
cblr-2960	277	25	taxes	taxis	NOUN
cblr-2960	277	26	saved	save	VERB
cblr-2960	277	27	.	.	PUNCT
cblr-2960	277	28	"	"	PUNCT
cblr-2960	278	1	i	i	PRON
cblr-2960	278	2	d.	d.	PROPN
cblr-2960	278	3	when	when	SCONJ
cblr-2960	278	4	the	the	DET
cblr-2960	278	5	anti	anti	ADJ
cblr-2960	278	6	-	-	ADJ
cblr-2960	278	7	avoidance	avoidance	ADJ
cblr-2960	278	8	measure	measure	NOUN
cblr-2960	278	9	is	be	AUX
cblr-2960	278	10	increased	increase	VERB
cblr-2960	278	11	,	,	PUNCT
cblr-2960	278	12	"	"	PUNCT
cblr-2960	278	13	some	some	DET
cblr-2960	278	14	taxpayers	taxpayer	NOUN
cblr-2960	278	15	who	who	PRON
cblr-2960	278	16	previously	previously	ADV
cblr-2960	278	17	avoided	avoid	VERB
cblr-2960	278	18	tax	tax	NOUN
cblr-2960	278	19	,	,	PUNCT
cblr-2960	278	20	those	those	PRON
cblr-2960	278	21	on	on	ADP
cblr-2960	278	22	the	the	DET
cblr-2960	278	23	margin	margin	NOUN
cblr-2960	278	24	,	,	PUNCT
cblr-2960	278	25	will	will	AUX
cblr-2960	278	26	stop	stop	VERB
cblr-2960	278	27	avoiding	avoid	VERB
cblr-2960	278	28	taxes	taxis	NOUN
cblr-2960	278	29	because	because	SCONJ
cblr-2960	278	30	avoidance	avoidance	NOUN
cblr-2960	278	31	has	have	AUX
cblr-2960	278	32	become	become	VERB
cblr-2960	278	33	too	too	ADV
cblr-2960	278	34	expensive	expensive	ADJ
cblr-2960	278	35	.	.	PUNCT
cblr-2960	278	36	"	"	PUNCT
cblr-2960	279	1	i	i	PRON
cblr-2960	279	2	d.	d.	PROPN
cblr-2960	279	3	other	other	ADJ
cblr-2960	279	4	taxpayers	taxpayer	NOUN
cblr-2960	279	5	,	,	PUNCT
cblr-2960	279	6	however	however	ADV
cblr-2960	279	7	,	,	PUNCT
cblr-2960	279	8	will	will	AUX
cblr-2960	279	9	continue	continue	VERB
cblr-2960	279	10	to	to	PART
cblr-2960	279	11	avoid	avoid	VERB
cblr-2960	279	12	tax	tax	NOUN
cblr-2960	279	13	,	,	PUNCT
cblr-2960	279	14	but	but	CCONJ
cblr-2960	279	15	now	now	ADV
cblr-2960	279	16	it	it	PRON
cblr-2960	279	17	is	be	AUX
cblr-2960	279	18	more	more	ADV
cblr-2960	279	19	costly	costly	ADJ
cblr-2960	279	20	to	to	PART
cblr-2960	279	21	do	do	VERB
cblr-2960	280	1	so	so	ADV
cblr-2960	280	2	they	they	PRON
cblr-2960	280	3	no	no	INTJ
cblr-2960	280	4	.	.	PUNCT
cblr-2960	281	1	2:694	2:694	NUM
cblr-2960	281	2	]	]	X
cblr-2960	281	3	columbia	columbia	PROPN
cblr-2960	281	4	business	business	PROPN
cblr-2960	281	5	law	law	PROPN
cblr-2960	281	6	review	review	NOUN
cblr-2960	281	7	for	for	ADP
cblr-2960	281	8	example	example	NOUN
cblr-2960	281	9	,	,	PUNCT
cblr-2960	281	10	suppose	suppose	VERB
cblr-2960	281	11	a	a	DET
cblr-2960	281	12	taxpayer	taxpayer	NOUN
cblr-2960	281	13	must	must	AUX
cblr-2960	281	14	pay	pay	VERB
cblr-2960	281	15	$	$	SYM
cblr-2960	281	16	50	50	NUM
cblr-2960	281	17	to	to	PART
cblr-2960	281	18	attain	attain	VERB
cblr-2960	281	19	a	a	DET
cblr-2960	281	20	$	$	SYM
cblr-2960	281	21	100	100	NUM
cblr-2960	281	22	tax	tax	NOUN
cblr-2960	281	23	benefit	benefit	NOUN
cblr-2960	281	24	.	.	PUNCT
cblr-2960	282	1	congress	congress	PROPN
cblr-2960	282	2	subsequently	subsequently	ADV
cblr-2960	282	3	enacts	enact	VERB
cblr-2960	282	4	a	a	DET
cblr-2960	282	5	tax	tax	NOUN
cblr-2960	282	6	rule	rule	NOUN
cblr-2960	282	7	that	that	PRON
cblr-2960	282	8	causes	cause	VERB
cblr-2960	282	9	the	the	DET
cblr-2960	282	10	taxpayer	taxpayer	NOUN
cblr-2960	282	11	to	to	PART
cblr-2960	282	12	incur	incur	VERB
cblr-2960	282	13	$	$	SYM
cblr-2960	282	14	70	70	NUM
cblr-2960	282	15	to	to	PART
cblr-2960	282	16	remain	remain	VERB
cblr-2960	282	17	in	in	ADP
cblr-2960	282	18	the	the	DET
cblr-2960	282	19	tax	tax	NOUN
cblr-2960	282	20	shelter	shelter	NOUN
cblr-2960	282	21	and	and	CCONJ
cblr-2960	282	22	attain	attain	VERB
cblr-2960	282	23	the	the	DET
cblr-2960	282	24	same	same	ADJ
cblr-2960	282	25	$	$	SYM
cblr-2960	282	26	100	100	NUM
cblr-2960	282	27	tax	tax	NOUN
cblr-2960	282	28	benefit	benefit	NOUN
cblr-2960	282	29	.	.	PUNCT
cblr-2960	283	1	because	because	SCONJ
cblr-2960	283	2	the	the	DET
cblr-2960	283	3	taxpayer	taxpayer	NOUN
cblr-2960	283	4	is	be	AUX
cblr-2960	283	5	still	still	ADV
cblr-2960	283	6	receiving	receive	VERB
cblr-2960	283	7	a	a	DET
cblr-2960	283	8	benefit	benefit	NOUN
cblr-2960	283	9	from	from	ADP
cblr-2960	283	10	the	the	DET
cblr-2960	283	11	transaction	transaction	NOUN
cblr-2960	283	12	,	,	PUNCT
cblr-2960	283	13	he	he	PRON
cblr-2960	283	14	will	will	AUX
cblr-2960	283	15	pay	pay	VERB
cblr-2960	283	16	the	the	DET
cblr-2960	283	17	extra	extra	ADJ
cblr-2960	283	18	$	$	SYM
cblr-2960	283	19	20	20	NUM
cblr-2960	283	20	to	to	PART
cblr-2960	283	21	sidestep	sidestep	VERB
cblr-2960	283	22	the	the	DET
cblr-2960	283	23	anti	anti	ADJ
cblr-2960	283	24	-	-	ADJ
cblr-2960	283	25	avoidance	avoidance	ADJ
cblr-2960	283	26	rule	rule	NOUN
cblr-2960	283	27	.	.	PUNCT
cblr-2960	284	1	although	although	SCONJ
cblr-2960	284	2	the	the	DET
cblr-2960	284	3	taxpayer	taxpayer	NOUN
cblr-2960	284	4	is	be	AUX
cblr-2960	284	5	paying	pay	VERB
cblr-2960	284	6	more	more	ADJ
cblr-2960	284	7	for	for	ADP
cblr-2960	284	8	the	the	DET
cblr-2960	284	9	relevant	relevant	ADJ
cblr-2960	284	10	tax	tax	NOUN
cblr-2960	284	11	shelter	shelter	NOUN
cblr-2960	284	12	,	,	PUNCT
cblr-2960	284	13	the	the	DET
cblr-2960	284	14	irs	irs	PROPN
cblr-2960	284	15	has	have	AUX
cblr-2960	284	16	not	not	PART
cblr-2960	284	17	increased	increase	VERB
cblr-2960	284	18	its	its	PRON
cblr-2960	284	19	tax	tax	NOUN
cblr-2960	284	20	revenue	revenue	NOUN
cblr-2960	284	21	.	.	PUNCT
cblr-2960	285	1	therefore	therefore	ADV
cblr-2960	285	2	,	,	PUNCT
cblr-2960	285	3	effective	effective	ADJ
cblr-2960	285	4	anti	anti	ADJ
cblr-2960	285	5	-	-	ADJ
cblr-2960	285	6	avoidance	avoidance	ADJ
cblr-2960	285	7	doctrines	doctrine	NOUN
cblr-2960	285	8	reduce	reduce	VERB
cblr-2960	285	9	the	the	DET
cblr-2960	285	10	taxpayer	taxpayer	NOUN
cblr-2960	285	11	's	's	PART
cblr-2960	285	12	elasticity	elasticity	NOUN
cblr-2960	285	13	of	of	ADP
cblr-2960	285	14	taxable	taxable	ADJ
cblr-2960	285	15	income	income	NOUN
cblr-2960	285	16	and	and	CCONJ
cblr-2960	285	17	limit	limit	VERB
cblr-2960	285	18	the	the	DET
cblr-2960	285	19	number	number	NOUN
cblr-2960	285	20	of	of	ADP
cblr-2960	285	21	taxpayers	taxpayer	NOUN
cblr-2960	285	22	that	that	PRON
cblr-2960	285	23	incur	incur	VERB
cblr-2960	285	24	higher	high	ADJ
cblr-2960	285	25	costs	cost	NOUN
cblr-2960	285	26	from	from	ADP
cblr-2960	285	27	remaining	remain	VERB
cblr-2960	285	28	in	in	ADP
cblr-2960	285	29	the	the	DET
cblr-2960	285	30	targeted	target	VERB
cblr-2960	285	31	shelter	shelter	NOUN
cblr-2960	285	32	.	.	PUNCT
cblr-2960	286	1	b.	b.	PROPN
cblr-2960	286	2	frictions	friction	VERB
cblr-2960	286	3	the	the	DET
cblr-2960	286	4	term	term	NOUN
cblr-2960	286	5	frictions	friction	NOUN
cblr-2960	286	6	characterize	characterize	VERB
cblr-2960	286	7	constraints	constraint	NOUN
cblr-2960	286	8	on	on	ADP
cblr-2960	286	9	tax	tax	NOUN
cblr-2960	286	10	planning	planning	NOUN
cblr-2960	286	11	outside	outside	ADP
cblr-2960	286	12	the	the	DET
cblr-2960	286	13	tax	tax	NOUN
cblr-2960	286	14	rules.88	rules.88	NOUN
cblr-2960	286	15	a	a	DET
cblr-2960	286	16	"	"	PUNCT
cblr-2960	286	17	discontinuous	discontinuous	ADJ
cblr-2960	286	18	"	"	PUNCT
cblr-2960	286	19	friction	friction	NOUN
cblr-2960	286	20	is	be	AUX
cblr-2960	286	21	defined	define	VERB
cblr-2960	286	22	as	as	ADP
cblr-2960	286	23	one	one	NUM
cblr-2960	286	24	that	that	PRON
cblr-2960	286	25	imposes	impose	VERB
cblr-2960	286	26	unavoidable	unavoidable	ADJ
cblr-2960	286	27	and	and	CCONJ
cblr-2960	286	28	significant	significant	ADJ
cblr-2960	286	29	costs	cost	NOUN
cblr-2960	286	30	when	when	SCONJ
cblr-2960	286	31	taxpayers	taxpayer	NOUN
cblr-2960	286	32	depart	depart	VERB
cblr-2960	286	33	from	from	ADP
cblr-2960	286	34	the	the	DET
cblr-2960	286	35	transaction	transaction	NOUN
cblr-2960	286	36	covered	cover	VERB
cblr-2960	286	37	by	by	ADP
cblr-2960	286	38	the	the	DET
cblr-2960	286	39	reform.89	reform.89	NOUN
cblr-2960	286	40	in	in	ADP
cblr-2960	286	41	contrast	contrast	NOUN
cblr-2960	286	42	,	,	PUNCT
cblr-2960	286	43	a	a	DET
cblr-2960	286	44	"	"	PUNCT
cblr-2960	286	45	continuous	continuous	ADJ
cblr-2960	286	46	"	"	PUNCT
cblr-2960	286	47	friction	friction	NOUN
cblr-2960	286	48	is	be	AUX
cblr-2960	286	49	an	an	DET
cblr-2960	286	50	inadequate	inadequate	ADJ
cblr-2960	286	51	deterrent	deterrent	NOUN
cblr-2960	286	52	that	that	PRON
cblr-2960	286	53	has	have	VERB
cblr-2960	286	54	a	a	DET
cblr-2960	286	55	minimal	minimal	ADJ
cblr-2960	286	56	or	or	CCONJ
cblr-2960	286	57	modest	modest	ADJ
cblr-2960	286	58	effect	effect	NOUN
cblr-2960	286	59	on	on	ADP
cblr-2960	286	60	taxpayer	taxpayer	NOUN
cblr-2960	286	61	welfare	welfare	NOUN
cblr-2960	286	62	,	,	PUNCT
cblr-2960	286	63	allowing	allow	VERB
cblr-2960	286	64	the	the	DET
cblr-2960	286	65	taxpayer	taxpayer	NOUN
cblr-2960	286	66	to	to	PART
cblr-2960	286	67	sidestep	sidestep	VERB
cblr-2960	286	68	the	the	DET
cblr-2960	286	69	reform	reform	NOUN
cblr-2960	286	70	while	while	SCONJ
cblr-2960	286	71	still	still	ADV
cblr-2960	286	72	engaging	engage	VERB
cblr-2960	286	73	in	in	ADP
cblr-2960	286	74	tax	tax	NOUN
cblr-2960	286	75	planning	planning	NOUN
cblr-2960	286	76	.	.	PUNCT
cblr-2960	287	1	°	°	PRON
cblr-2960	287	2	four	four	NUM
cblr-2960	287	3	factors	factor	NOUN
cblr-2960	287	4	determine	determine	VERB
cblr-2960	287	5	whether	whether	SCONJ
cblr-2960	287	6	frictions	friction	NOUN
cblr-2960	287	7	will	will	AUX
cblr-2960	287	8	be	be	AUX
cblr-2960	287	9	effective	effective	ADJ
cblr-2960	287	10	in	in	ADP
cblr-2960	287	11	the	the	DET
cblr-2960	287	12	prevention	prevention	NOUN
cblr-2960	287	13	of	of	ADP
cblr-2960	287	14	tax	tax	NOUN
cblr-2960	287	15	avoidance	avoidance	NOUN
cblr-2960	287	16	.	.	PUNCT
cblr-2960	288	1	first	first	ADV
cblr-2960	288	2	,	,	PUNCT
cblr-2960	288	3	the	the	DET
cblr-2960	288	4	size	size	NOUN
cblr-2960	288	5	of	of	ADP
cblr-2960	288	6	the	the	DET
cblr-2960	288	7	benefit	benefit	NOUN
cblr-2960	288	8	that	that	SCONJ
cblr-2960	288	9	tax	tax	NOUN
cblr-2960	288	10	planning	planning	NOUN
cblr-2960	288	11	provides.9	provides.9	PROPN
cblr-2960	288	12	1	1	NUM
cblr-2960	288	13	when	when	SCONJ
cblr-2960	288	14	the	the	DET
cblr-2960	288	15	benefit	benefit	NOUN
cblr-2960	288	16	is	be	AUX
cblr-2960	288	17	larger	large	ADJ
cblr-2960	288	18	,	,	PUNCT
cblr-2960	288	19	the	the	PRON
cblr-2960	288	20	must	must	AUX
cblr-2960	288	21	engage	engage	VERB
cblr-2960	288	22	in	in	ADP
cblr-2960	288	23	more	more	ADV
cblr-2960	288	24	elaborate	elaborate	ADJ
cblr-2960	288	25	shelters	shelter	NOUN
cblr-2960	288	26	to	to	PART
cblr-2960	288	27	avoid	avoid	VERB
cblr-2960	288	28	tax	tax	NOUN
cblr-2960	288	29	,	,	PUNCT
cblr-2960	288	30	incurring	incur	VERB
cblr-2960	288	31	additional	additional	ADJ
cblr-2960	288	32	costs	cost	NOUN
cblr-2960	288	33	.	.	PUNCT
cblr-2960	289	1	i	i	PRON
cblr-2960	289	2	d.	d.	PROPN
cblr-2960	289	3	'	'	PUNCT
cblr-2960	289	4	see	see	PROPN
cblr-2960	289	5	schizer	schizer	NOUN
cblr-2960	289	6	,	,	PUNCT
cblr-2960	289	7	supra	supra	PROPN
cblr-2960	289	8	note	note	NOUN
cblr-2960	289	9	20	20	NUM
cblr-2960	289	10	,	,	PUNCT
cblr-2960	289	11	at	at	ADP
cblr-2960	289	12	1315	1315	NUM
cblr-2960	289	13	(	(	PUNCT
cblr-2960	289	14	noting	note	VERB
cblr-2960	289	15	that	that	SCONJ
cblr-2960	289	16	frictions	friction	NOUN
cblr-2960	289	17	"	"	PUNCT
cblr-2960	289	18	describe	describe	VERB
cblr-2960	289	19	constraints	constraint	NOUN
cblr-2960	289	20	on	on	ADP
cblr-2960	289	21	tax	tax	NOUN
cblr-2960	289	22	planning	planning	NOUN
cblr-2960	289	23	external	external	ADJ
cblr-2960	289	24	to	to	ADP
cblr-2960	289	25	the	the	DET
cblr-2960	289	26	tax	tax	NOUN
cblr-2960	289	27	law	law	NOUN
cblr-2960	289	28	"	"	PUNCT
cblr-2960	289	29	)	)	PUNCT
cblr-2960	289	30	.	.	PUNCT
cblr-2960	290	1	'	'	NUM
cblr-2960	290	2	9	9	NUM
cblr-2960	290	3	i	i	PRON
cblr-2960	290	4	d.	d.	PROPN
cblr-2960	290	5	at	at	ADP
cblr-2960	290	6	1325	1325	NUM
cblr-2960	290	7	(	(	PUNCT
cblr-2960	290	8	explaining	explain	VERB
cblr-2960	290	9	that	that	DET
cblr-2960	290	10	avoidance	avoidance	NOUN
cblr-2960	290	11	is	be	AUX
cblr-2960	290	12	unlikely	unlikely	ADJ
cblr-2960	290	13	if	if	SCONJ
cblr-2960	290	14	,	,	PUNCT
cblr-2960	290	15	"	"	PUNCT
cblr-2960	290	16	in	in	ADP
cblr-2960	290	17	changing	change	VERB
cblr-2960	290	18	the	the	DET
cblr-2960	290	19	transaction	transaction	NOUN
cblr-2960	290	20	to	to	PART
cblr-2960	290	21	avoid	avoid	VERB
cblr-2960	290	22	the	the	DET
cblr-2960	290	23	reform	reform	NOUN
cblr-2960	290	24	,	,	PUNCT
cblr-2960	290	25	the	the	DET
cblr-2960	290	26	taxpayer	taxpayer	NOUN
cblr-2960	290	27	or	or	CCONJ
cblr-2960	290	28	an	an	DET
cblr-2960	290	29	irreplaceable	irreplaceable	ADJ
cblr-2960	290	30	counterparty	counterparty	NOUN
cblr-2960	290	31	would	would	AUX
cblr-2960	290	32	suffer	suffer	VERB
cblr-2960	290	33	a	a	DET
cblr-2960	290	34	dramatic	dramatic	ADJ
cblr-2960	290	35	and	and	CCONJ
cblr-2960	290	36	unavoidable	unavoidable	ADJ
cblr-2960	290	37	decline	decline	NOUN
cblr-2960	290	38	in	in	ADP
cblr-2960	290	39	utility	utility	NOUN
cblr-2960	290	40	,	,	PUNCT
cblr-2960	290	41	and	and	CCONJ
cblr-2960	290	42	this	this	DET
cblr-2960	290	43	cost	cost	NOUN
cblr-2960	290	44	would	would	AUX
cblr-2960	290	45	exceed	exceed	VERB
cblr-2960	290	46	the	the	DET
cblr-2960	290	47	tax	tax	NOUN
cblr-2960	290	48	benefit	benefit	NOUN
cblr-2960	290	49	at	at	ADP
cblr-2960	290	50	issue	issue	NOUN
cblr-2960	290	51	"	"	PUNCT
cblr-2960	290	52	)	)	PUNCT
cblr-2960	290	53	.	.	PUNCT
cblr-2960	291	1	"	"	PUNCT
cblr-2960	292	1	i	i	PRON
cblr-2960	292	2	d.	d.	PROPN
cblr-2960	292	3	at	at	ADP
cblr-2960	292	4	1326	1326	NUM
cblr-2960	292	5	(	(	PUNCT
cblr-2960	292	6	explaining	explain	VERB
cblr-2960	292	7	that	that	SCONJ
cblr-2960	292	8	a	a	DET
cblr-2960	292	9	"	"	PUNCT
cblr-2960	292	10	continuous	continuous	ADJ
cblr-2960	292	11	"	"	PUNCT
cblr-2960	292	12	friction	friction	NOUN
cblr-2960	292	13	will	will	AUX
cblr-2960	292	14	have	have	VERB
cblr-2960	292	15	only	only	ADV
cblr-2960	292	16	a	a	DET
cblr-2960	292	17	modest	modest	ADJ
cblr-2960	292	18	effect	effect	NOUN
cblr-2960	292	19	on	on	ADP
cblr-2960	292	20	taxpayer	taxpayer	NOUN
cblr-2960	292	21	welfare	welfare	NOUN
cblr-2960	292	22	and	and	CCONJ
cblr-2960	292	23	is	be	AUX
cblr-2960	292	24	less	less	ADV
cblr-2960	292	25	likely	likely	ADJ
cblr-2960	292	26	to	to	PART
cblr-2960	292	27	prevent	prevent	VERB
cblr-2960	292	28	avoidance	avoidance	NOUN
cblr-2960	292	29	of	of	ADP
cblr-2960	292	30	a	a	DET
cblr-2960	292	31	tax	tax	NOUN
cblr-2960	292	32	rule	rule	NOUN
cblr-2960	292	33	)	)	PUNCT
cblr-2960	292	34	.	.	PUNCT
cblr-2960	293	1	"	"	PUNCT
cblr-2960	293	2	if	if	SCONJ
cblr-2960	293	3	a	a	DET
cblr-2960	293	4	larger	large	ADJ
cblr-2960	293	5	tax	tax	NOUN
cblr-2960	293	6	benefit	benefit	NOUN
cblr-2960	293	7	is	be	AUX
cblr-2960	293	8	at	at	ADP
cblr-2960	293	9	issue	issue	NOUN
cblr-2960	293	10	,	,	PUNCT
cblr-2960	293	11	a	a	DET
cblr-2960	293	12	more	more	ADV
cblr-2960	293	13	persuasive	persuasive	ADJ
cblr-2960	293	14	friction	friction	NOUN
cblr-2960	293	15	is	be	AUX
cblr-2960	293	16	required	require	VERB
cblr-2960	293	17	in	in	ADP
cblr-2960	293	18	order	order	NOUN
cblr-2960	293	19	for	for	SCONJ
cblr-2960	293	20	the	the	DET
cblr-2960	293	21	rule	rule	NOUN
cblr-2960	293	22	to	to	PART
cblr-2960	293	23	be	be	AUX
cblr-2960	293	24	effective	effective	ADJ
cblr-2960	293	25	.	.	PUNCT
cblr-2960	294	1	furthermore	furthermore	ADV
cblr-2960	294	2	,	,	PUNCT
cblr-2960	294	3	the	the	DET
cblr-2960	294	4	applicable	applicable	ADJ
cblr-2960	294	5	tax	tax	NOUN
cblr-2960	294	6	rate	rate	NOUN
cblr-2960	294	7	and	and	CCONJ
cblr-2960	294	8	the	the	DET
cblr-2960	294	9	amount	amount	NOUN
cblr-2960	294	10	of	of	ADP
cblr-2960	294	11	income	income	NOUN
cblr-2960	294	12	at	at	ADP
cblr-2960	294	13	stake	stake	NOUN
cblr-2960	294	14	are	be	AUX
cblr-2960	294	15	pertinent	pertinent	ADJ
cblr-2960	294	16	questions	question	NOUN
cblr-2960	294	17	in	in	ADP
cblr-2960	294	18	determining	determine	VERB
cblr-2960	294	19	whether	whether	SCONJ
cblr-2960	294	20	frictions	friction	NOUN
cblr-2960	294	21	may	may	AUX
cblr-2960	294	22	be	be	AUX
cblr-2960	294	23	effective	effective	ADJ
cblr-2960	294	24	.	.	PUNCT
cblr-2960	295	1	i	i	PRON
cblr-2960	295	2	d.	d.	PROPN
cblr-2960	295	3	at	at	ADP
cblr-2960	295	4	1323	1323	NUM
cblr-2960	295	5	-	-	SYM
cblr-2960	295	6	24	24	NUM
cblr-2960	295	7	.	.	PUNCT
cblr-2960	296	1	[	[	X
cblr-2960	296	2	vol	vol	NOUN
cblr-2960	296	3	.	.	NOUN
cblr-2960	296	4	2008	2008	NUM
cblr-2960	296	5	job	job	NOUN
cblr-2960	296	6	well	well	ADV
cblr-2960	296	7	done	do	VERB
cblr-2960	296	8	friction	friction	NOUN
cblr-2960	296	9	will	will	AUX
cblr-2960	296	10	need	need	VERB
cblr-2960	296	11	to	to	PART
cblr-2960	296	12	be	be	AUX
cblr-2960	296	13	stronger.92	stronger.92	NOUN
cblr-2960	296	14	second	second	ADJ
cblr-2960	296	15	,	,	PUNCT
cblr-2960	296	16	the	the	DET
cblr-2960	296	17	"	"	PUNCT
cblr-2960	296	18	strength	strength	NOUN
cblr-2960	296	19	"	"	PUNCT
cblr-2960	296	20	of	of	ADP
cblr-2960	296	21	the	the	DET
cblr-2960	296	22	friction	friction	NOUN
cblr-2960	296	23	measures	measure	VERB
cblr-2960	296	24	the	the	DET
cblr-2960	296	25	inconvenience	inconvenience	NOUN
cblr-2960	296	26	to	to	ADP
cblr-2960	296	27	the	the	DET
cblr-2960	296	28	taxpayer.93	taxpayer.93	NOUN
cblr-2960	296	29	for	for	ADP
cblr-2960	296	30	example	example	NOUN
cblr-2960	296	31	,	,	PUNCT
cblr-2960	296	32	if	if	SCONJ
cblr-2960	296	33	a	a	DET
cblr-2960	296	34	taxpayer	taxpayer	NOUN
cblr-2960	296	35	incurs	incur	VERB
cblr-2960	296	36	a	a	DET
cblr-2960	296	37	cost	cost	NOUN
cblr-2960	296	38	that	that	PRON
cblr-2960	296	39	is	be	AUX
cblr-2960	296	40	still	still	ADV
cblr-2960	296	41	less	less	ADJ
cblr-2960	296	42	than	than	ADP
cblr-2960	296	43	the	the	DET
cblr-2960	296	44	tax	tax	NOUN
cblr-2960	296	45	planning	planning	NOUN
cblr-2960	296	46	benefit	benefit	NOUN
cblr-2960	296	47	,	,	PUNCT
cblr-2960	296	48	the	the	DET
cblr-2960	296	49	friction	friction	NOUN
cblr-2960	296	50	is	be	AUX
cblr-2960	296	51	weak	weak	ADJ
cblr-2960	296	52	and	and	CCONJ
cblr-2960	296	53	the	the	DET
cblr-2960	296	54	taxpayer	taxpayer	NOUN
cblr-2960	296	55	will	will	AUX
cblr-2960	296	56	continue	continue	VERB
cblr-2960	296	57	to	to	PART
cblr-2960	296	58	engage	engage	VERB
cblr-2960	296	59	in	in	ADP
cblr-2960	296	60	the	the	DET
cblr-2960	296	61	targeted	target	VERB
cblr-2960	296	62	transaction.94	transaction.94	NOUN
cblr-2960	296	63	third	third	ADJ
cblr-2960	296	64	,	,	PUNCT
cblr-2960	296	65	the	the	DET
cblr-2960	296	66	"	"	PUNCT
cblr-2960	296	67	malleability	malleability	NOUN
cblr-2960	296	68	"	"	PUNCT
cblr-2960	296	69	or	or	CCONJ
cblr-2960	296	70	"	"	PUNCT
cblr-2960	296	71	rigidity	rigidity	NOUN
cblr-2960	296	72	"	"	PUNCT
cblr-2960	296	73	of	of	ADP
cblr-2960	296	74	the	the	DET
cblr-2960	296	75	friction	friction	NOUN
cblr-2960	296	76	examines	examine	VERB
cblr-2960	296	77	the	the	DET
cblr-2960	296	78	ability	ability	NOUN
cblr-2960	296	79	of	of	ADP
cblr-2960	296	80	taxpayers	taxpayer	NOUN
cblr-2960	296	81	to	to	PART
cblr-2960	296	82	tweak	tweak	VERB
cblr-2960	296	83	the	the	DET
cblr-2960	296	84	deal	deal	NOUN
cblr-2960	296	85	just	just	ADV
cblr-2960	296	86	enough	enough	ADV
cblr-2960	296	87	to	to	PART
cblr-2960	296	88	attain	attain	VERB
cblr-2960	296	89	the	the	DET
cblr-2960	296	90	tax	tax	NOUN
cblr-2960	296	91	benefit	benefit	NOUN
cblr-2960	296	92	.	.	PUNCT
cblr-2960	297	1	taxpayers	taxpayer	NOUN
cblr-2960	297	2	must	must	AUX
cblr-2960	297	3	be	be	AUX
cblr-2960	297	4	forced	force	VERB
cblr-2960	297	5	to	to	PART
cblr-2960	297	6	choose	choose	VERB
cblr-2960	297	7	between	between	ADP
cblr-2960	297	8	the	the	DET
cblr-2960	297	9	friction	friction	NOUN
cblr-2960	297	10	and	and	CCONJ
cblr-2960	297	11	the	the	DET
cblr-2960	297	12	tax	tax	NOUN
cblr-2960	297	13	benefit.95	benefit.95	PROPN
cblr-2960	297	14	fourth	fourth	ADJ
cblr-2960	297	15	,	,	PUNCT
cblr-2960	297	16	frictions	friction	NOUN
cblr-2960	297	17	that	that	PRON
cblr-2960	297	18	make	make	VERB
cblr-2960	297	19	it	it	PRON
cblr-2960	297	20	more	more	ADV
cblr-2960	297	21	difficult	difficult	ADJ
cblr-2960	297	22	for	for	SCONJ
cblr-2960	297	23	practitioners	practitioner	NOUN
cblr-2960	297	24	and	and	CCONJ
cblr-2960	297	25	other	other	ADJ
cblr-2960	297	26	tax	tax	NOUN
cblr-2960	297	27	accommodation	accommodation	NOUN
cblr-2960	297	28	parties	party	NOUN
cblr-2960	297	29	such	such	ADJ
cblr-2960	297	30	as	as	ADP
cblr-2960	297	31	advisors	advisor	NOUN
cblr-2960	297	32	or	or	CCONJ
cblr-2960	297	33	potential	potential	ADJ
cblr-2960	297	34	counterparties	counterpartie	NOUN
cblr-2960	297	35	to	to	PART
cblr-2960	297	36	aid	aid	VERB
cblr-2960	297	37	the	the	DET
cblr-2960	297	38	taxpayer	taxpayer	NOUN
cblr-2960	297	39	in	in	ADP
cblr-2960	297	40	planning	planning	NOUN
cblr-2960	297	41	are	be	AUX
cblr-2960	297	42	more	more	ADV
cblr-2960	297	43	effective	effective	ADJ
cblr-2960	297	44	in	in	ADP
cblr-2960	297	45	curtailing	curtail	VERB
cblr-2960	297	46	the	the	DET
cblr-2960	297	47	relevant	relevant	ADJ
cblr-2960	297	48	planning	planning	NOUN
cblr-2960	297	49	mechanism.96	mechanism.96	PROPN
cblr-2960	297	50	ultimately	ultimately	ADV
cblr-2960	297	51	,	,	PUNCT
cblr-2960	297	52	effective	effective	ADJ
cblr-2960	297	53	frictions	friction	NOUN
cblr-2960	297	54	demonstrate	demonstrate	VERB
cblr-2960	297	55	that	that	SCONJ
cblr-2960	297	56	an	an	DET
cblr-2960	297	57	anti	anti	ADJ
cblr-2960	297	58	-	-	ADJ
cblr-2960	297	59	avoidance	avoidance	ADJ
cblr-2960	297	60	doctrine	doctrine	NOUN
cblr-2960	297	61	efficiently	efficiently	ADV
cblr-2960	297	62	constrains	constrain	VERB
cblr-2960	297	63	the	the	DET
cblr-2960	297	64	use	use	NOUN
cblr-2960	297	65	of	of	ADP
cblr-2960	297	66	a	a	DET
cblr-2960	297	67	tax	tax	NOUN
cblr-2960	297	68	planning	planning	NOUN
cblr-2960	297	69	device	device	NOUN
cblr-2960	297	70	.	.	PUNCT
cblr-2960	298	1	v.	v.	ADP
cblr-2960	298	2	efficiency	efficiency	NOUN
cblr-2960	298	3	analysis	analysis	NOUN
cblr-2960	298	4	the	the	DET
cblr-2960	298	5	treasury	treasury	PROPN
cblr-2960	298	6	regulations	regulation	NOUN
cblr-2960	298	7	and	and	CCONJ
cblr-2960	298	8	recent	recent	ADJ
cblr-2960	298	9	irs	irs	PROPN
cblr-2960	298	10	rulings	ruling	NOUN
cblr-2960	298	11	are	be	AUX
cblr-2960	298	12	aimed	aim	VERB
cblr-2960	298	13	at	at	ADP
cblr-2960	298	14	preventing	prevent	VERB
cblr-2960	298	15	sophisticated	sophisticated	ADJ
cblr-2960	298	16	investors	investor	NOUN
cblr-2960	298	17	from	from	ADP
cblr-2960	298	18	using	use	VERB
cblr-2960	298	19	life	life	NOUN
cblr-2960	298	20	insurance	insurance	NOUN
cblr-2960	298	21	to	to	PART
cblr-2960	298	22	turn	turn	VERB
cblr-2960	298	23	taxable	taxable	ADJ
cblr-2960	298	24	investments	investment	NOUN
cblr-2960	298	25	in	in	ADP
cblr-2960	298	26	hedge	hedge	NOUN
cblr-2960	298	27	funds	fund	NOUN
cblr-2960	298	28	into	into	ADP
cblr-2960	298	29	tax	tax	NOUN
cblr-2960	298	30	-	-	PUNCT
cblr-2960	298	31	deferred	defer	VERB
cblr-2960	298	32	or	or	CCONJ
cblr-2960	298	33	tax	tax	NOUN
cblr-2960	298	34	-	-	PUNCT
cblr-2960	298	35	free	free	ADJ
cblr-2960	298	36	investments.97	investments.97	NOUN
cblr-2960	298	37	instead	instead	ADV
cblr-2960	298	38	of	of	ADP
cblr-2960	298	39	prohibiting	prohibit	VERB
cblr-2960	298	40	92	92	NUM
cblr-2960	298	41	i	i	PROPN
cblr-2960	298	42	d.	d.	PROPN
cblr-2960	298	43	93	93	NUM
cblr-2960	299	1	i	i	PRON
cblr-2960	299	2	d.	d.	PROPN
cblr-2960	299	3	at	at	ADP
cblr-2960	299	4	1324	1324	NUM
cblr-2960	299	5	.	.	PUNCT
cblr-2960	300	1	9	9	NUM
cblr-2960	300	2	'	'	PUNCT
cblr-2960	300	3	i	i	PRON
cblr-2960	300	4	d.	d.	PROPN
cblr-2960	300	5	at	at	ADP
cblr-2960	300	6	1325	1325	NUM
cblr-2960	300	7	(	(	PUNCT
cblr-2960	300	8	showing	show	VERB
cblr-2960	300	9	that	that	SCONJ
cblr-2960	300	10	if	if	SCONJ
cblr-2960	300	11	an	an	DET
cblr-2960	300	12	increased	increase	VERB
cblr-2960	300	13	cost	cost	NOUN
cblr-2960	300	14	is	be	AUX
cblr-2960	300	15	less	less	ADJ
cblr-2960	300	16	than	than	ADP
cblr-2960	300	17	the	the	DET
cblr-2960	300	18	tax	tax	NOUN
cblr-2960	300	19	savings	saving	NOUN
cblr-2960	300	20	,	,	PUNCT
cblr-2960	300	21	the	the	DET
cblr-2960	300	22	friction	friction	NOUN
cblr-2960	300	23	is	be	AUX
cblr-2960	300	24	too	too	ADV
cblr-2960	300	25	weak	weak	ADJ
cblr-2960	300	26	to	to	PART
cblr-2960	300	27	stop	stop	VERB
cblr-2960	300	28	the	the	DET
cblr-2960	300	29	targeted	target	VERB
cblr-2960	300	30	tax	tax	NOUN
cblr-2960	300	31	planning	planning	NOUN
cblr-2960	300	32	)	)	PUNCT
cblr-2960	300	33	.	.	PUNCT
cblr-2960	300	34	"	"	PUNCT
cblr-2960	301	1	i	i	PRON
cblr-2960	301	2	d.	d.	VERB
cblr-2960	301	3	at	at	ADP
cblr-2960	301	4	1324	1324	NUM
cblr-2960	301	5	-	-	SYM
cblr-2960	301	6	25	25	NUM
cblr-2960	301	7	(	(	PUNCT
cblr-2960	301	8	explaining	explain	VERB
cblr-2960	301	9	that	that	SCONJ
cblr-2960	301	10	malleability	malleability	NOUN
cblr-2960	301	11	relates	relate	VERB
cblr-2960	301	12	to	to	ADP
cblr-2960	301	13	"	"	PUNCT
cblr-2960	301	14	how	how	SCONJ
cblr-2960	301	15	difficult	difficult	ADJ
cblr-2960	301	16	it	it	PRON
cblr-2960	301	17	is	be	AUX
cblr-2960	301	18	for	for	SCONJ
cblr-2960	301	19	the	the	DET
cblr-2960	301	20	taxpayer	taxpayer	NOUN
cblr-2960	301	21	to	to	PART
cblr-2960	301	22	attain	attain	VERB
cblr-2960	301	23	the	the	DET
cblr-2960	301	24	benefits	benefit	NOUN
cblr-2960	301	25	of	of	ADP
cblr-2960	301	26	the	the	DET
cblr-2960	301	27	friction	friction	NOUN
cblr-2960	301	28	,	,	PUNCT
cblr-2960	301	29	or	or	CCONJ
cblr-2960	301	30	to	to	PART
cblr-2960	301	31	avoid	avoid	VERB
cblr-2960	301	32	the	the	DET
cblr-2960	301	33	costs	cost	NOUN
cblr-2960	301	34	it	it	PRON
cblr-2960	301	35	imposes	impose	VERB
cblr-2960	301	36	,	,	PUNCT
cblr-2960	301	37	while	while	SCONJ
cblr-2960	301	38	still	still	ADV
cblr-2960	301	39	achieving	achieve	VERB
cblr-2960	301	40	the	the	DET
cblr-2960	301	41	tax	tax	NOUN
cblr-2960	301	42	objective	objective	NOUN
cblr-2960	301	43	"	"	PUNCT
cblr-2960	301	44	)	)	PUNCT
cblr-2960	301	45	.	.	PUNCT
cblr-2960	302	1	9	9	NUM
cblr-2960	302	2	for	for	ADP
cblr-2960	302	3	example	example	NOUN
cblr-2960	302	4	,	,	PUNCT
cblr-2960	302	5	"	"	PUNCT
cblr-2960	302	6	if	if	SCONJ
cblr-2960	302	7	the	the	DET
cblr-2960	302	8	taxpayer	taxpayer	NOUN
cblr-2960	302	9	must	must	AUX
cblr-2960	302	10	have	have	VERB
cblr-2960	302	11	a	a	DET
cblr-2960	302	12	legal	legal	ADJ
cblr-2960	302	13	opinion	opinion	NOUN
cblr-2960	302	14	in	in	ADP
cblr-2960	302	15	order	order	NOUN
cblr-2960	302	16	to	to	PART
cblr-2960	302	17	avoid	avoid	VERB
cblr-2960	302	18	penalties	penalty	NOUN
cblr-2960	302	19	,	,	PUNCT
cblr-2960	302	20	frictions	friction	NOUN
cblr-2960	302	21	that	that	PRON
cblr-2960	302	22	discourage	discourage	VERB
cblr-2960	302	23	counsel	counsel	NOUN
cblr-2960	302	24	from	from	ADP
cblr-2960	302	25	rendering	render	VERB
cblr-2960	302	26	the	the	DET
cblr-2960	302	27	opinion	opinion	NOUN
cblr-2960	302	28	will	will	AUX
cblr-2960	302	29	impede	impede	VERB
cblr-2960	302	30	planning	plan	VERB
cblr-2960	302	31	.	.	PUNCT
cblr-2960	302	32	"	"	PUNCT
cblr-2960	303	1	i	i	PRON
cblr-2960	303	2	d.	d.	PROPN
cblr-2960	303	3	at	at	ADP
cblr-2960	303	4	1325	1325	NUM
cblr-2960	303	5	.	.	PUNCT
cblr-2960	304	1	in	in	ADP
cblr-2960	304	2	addition	addition	NOUN
cblr-2960	304	3	,	,	PUNCT
cblr-2960	304	4	"	"	PUNCT
cblr-2960	304	5	if	if	SCONJ
cblr-2960	304	6	the	the	DET
cblr-2960	304	7	taxpayer	taxpayer	NOUN
cblr-2960	304	8	needs	need	VERB
cblr-2960	304	9	a	a	DET
cblr-2960	304	10	securities	security	NOUN
cblr-2960	304	11	dealer	dealer	NOUN
cblr-2960	304	12	for	for	ADP
cblr-2960	304	13	a	a	DET
cblr-2960	304	14	planning	planning	NOUN
cblr-2960	304	15	strategy	strategy	NOUN
cblr-2960	304	16	,	,	PUNCT
cblr-2960	304	17	"	"	PUNCT
cblr-2960	304	18	effective	effective	ADJ
cblr-2960	304	19	frictions	friction	NOUN
cblr-2960	304	20	will	will	AUX
cblr-2960	304	21	prevent	prevent	VERB
cblr-2960	304	22	the	the	DET
cblr-2960	304	23	dealer	dealer	NOUN
cblr-2960	304	24	from	from	ADP
cblr-2960	304	25	supplying	supply	VERB
cblr-2960	304	26	the	the	DET
cblr-2960	304	27	requisite	requisite	ADJ
cblr-2960	304	28	security	security	NOUN
cblr-2960	304	29	.	.	PUNCT
cblr-2960	305	1	i	i	PRON
cblr-2960	305	2	d.	d.	PROPN
cblr-2960	305	3	"	"	PUNCT
cblr-2960	305	4	rob	rob	PROPN
cblr-2960	305	5	wells	wells	PROPN
cblr-2960	305	6	,	,	PUNCT
cblr-2960	305	7	treasury	treasury	NOUN
cblr-2960	305	8	curbs	curb	NOUN
cblr-2960	305	9	tax	tax	NOUN
cblr-2960	305	10	-	-	PUNCT
cblr-2960	305	11	deferral	deferral	ADJ
cblr-2960	305	12	strategy	strategy	NOUN
cblr-2960	305	13	new	new	ADJ
cblr-2960	305	14	regulations	regulation	NOUN
cblr-2960	305	15	limit	limit	VERB
cblr-2960	305	16	use	use	NOUN
cblr-2960	305	17	of	of	ADP
cblr-2960	305	18	insurance	insurance	NOUN
cblr-2960	305	19	,	,	PUNCT
cblr-2960	305	20	annuities	annuity	NOUN
cblr-2960	305	21	by	by	ADP
cblr-2960	305	22	sophisticated	sophisticated	ADJ
cblr-2960	305	23	investors	investor	NOUN
cblr-2960	305	24	,	,	PUNCT
cblr-2960	305	25	wall	wall	PROPN
cblr-2960	305	26	st	st	PROPN
cblr-2960	305	27	.	.	PROPN
cblr-2960	305	28	j.	j.	PROPN
cblr-2960	305	29	,	,	PUNCT
cblr-2960	305	30	mar	mar	PROPN
cblr-2960	305	31	.	.	PROPN
cblr-2960	305	32	1	1	NUM
cblr-2960	305	33	,	,	PUNCT
cblr-2960	305	34	2005	2005	NUM
cblr-2960	305	35	,	,	PUNCT
cblr-2960	305	36	at	at	ADP
cblr-2960	305	37	d2	d2	PROPN
cblr-2960	305	38	(	(	PUNCT
cblr-2960	305	39	discussing	discuss	VERB
cblr-2960	305	40	the	the	DET
cblr-2960	305	41	treasury	treasury	PROPN
cblr-2960	305	42	department	department	NOUN
cblr-2960	305	43	's	's	PART
cblr-2960	305	44	release	release	NOUN
cblr-2960	305	45	of	of	ADP
cblr-2960	305	46	final	final	ADJ
cblr-2960	305	47	rules	rule	NOUN
cblr-2960	305	48	limiting	limit	VERB
cblr-2960	305	49	the	the	DET
cblr-2960	305	50	use	use	NOUN
cblr-2960	305	51	of	of	ADP
cblr-2960	305	52	life	life	NOUN
cblr-2960	305	53	insurance	insurance	NOUN
cblr-2960	305	54	and	and	CCONJ
cblr-2960	305	55	annuities	annuity	NOUN
cblr-2960	305	56	to	to	PART
cblr-2960	305	57	avoid	avoid	VERB
cblr-2960	305	58	current	current	ADJ
cblr-2960	305	59	taxes	taxis	NOUN
cblr-2960	305	60	on	on	ADP
cblr-2960	305	61	investment	investment	NOUN
cblr-2960	305	62	earnings	earning	NOUN
cblr-2960	305	63	in	in	ADP
cblr-2960	305	64	hedge	hedge	NOUN
cblr-2960	305	65	funds	fund	NOUN
cblr-2960	305	66	and	and	CCONJ
cblr-2960	305	67	other	other	ADJ
cblr-2960	305	68	private	private	ADJ
cblr-2960	305	69	placement	placement	NOUN
cblr-2960	305	70	investments	investment	NOUN
cblr-2960	305	71	)	)	PUNCT
cblr-2960	305	72	.	.	PUNCT
cblr-2960	306	1	no	no	INTJ
cblr-2960	306	2	,	,	PUNCT
cblr-2960	306	3	2:694	2:694	NUM
cblr-2960	306	4	]	]	X
cblr-2960	306	5	columbia	columbia	PROPN
cblr-2960	306	6	business	business	PROPN
cblr-2960	306	7	law	law	PROPN
cblr-2960	306	8	re	re	PROPN
cblr-2960	306	9	vie	vie	PROPN
cblr-2960	306	10	w	w	PROPN
cblr-2960	306	11	these	these	DET
cblr-2960	306	12	transactions	transaction	NOUN
cblr-2960	306	13	,	,	PUNCT
cblr-2960	306	14	the	the	DET
cblr-2960	306	15	recent	recent	ADJ
cblr-2960	306	16	changes	change	NOUN
cblr-2960	306	17	provide	provide	VERB
cblr-2960	306	18	a	a	DET
cblr-2960	306	19	roadmap	roadmap	NOUN
cblr-2960	306	20	to	to	ADP
cblr-2960	306	21	the	the	DET
cblr-2960	306	22	industry	industry	NOUN
cblr-2960	306	23	and	and	CCONJ
cblr-2960	306	24	investors	investor	NOUN
cblr-2960	306	25	,	,	PUNCT
cblr-2960	306	26	enabling	enable	VERB
cblr-2960	306	27	them	they	PRON
cblr-2960	306	28	to	to	PART
cblr-2960	306	29	proceed	proceed	VERB
cblr-2960	306	30	confidently	confidently	ADV
cblr-2960	306	31	with	with	ADP
cblr-2960	306	32	private	private	ADJ
cblr-2960	306	33	placement	placement	NOUN
cblr-2960	306	34	products	product	NOUN
cblr-2960	306	35	as	as	ADV
cblr-2960	306	36	long	long	ADV
cblr-2960	306	37	as	as	SCONJ
cblr-2960	306	38	they	they	PRON
cblr-2960	306	39	are	be	AUX
cblr-2960	306	40	structured	structure	VERB
cblr-2960	306	41	within	within	ADP
cblr-2960	306	42	the	the	DET
cblr-2960	306	43	service	service	NOUN
cblr-2960	306	44	's	's	PART
cblr-2960	306	45	prescripts	prescript	NOUN
cblr-2960	306	46	.	.	PUNCT
cblr-2960	306	47	"	"	PUNCT
cblr-2960	307	1	it	it	PRON
cblr-2960	307	2	is	be	AUX
cblr-2960	307	3	clear	clear	ADJ
cblr-2960	307	4	that	that	SCONJ
cblr-2960	307	5	the	the	DET
cblr-2960	307	6	tax	tax	NOUN
cblr-2960	307	7	agencies	agency	NOUN
cblr-2960	307	8	have	have	AUX
cblr-2960	307	9	given	give	VERB
cblr-2960	307	10	their	their	PRON
cblr-2960	307	11	blessing	blessing	NOUN
cblr-2960	307	12	to	to	ADP
cblr-2960	307	13	life	life	NOUN
cblr-2960	307	14	insurance	insurance	NOUN
cblr-2960	307	15	policies	policy	NOUN
cblr-2960	307	16	that	that	PRON
cblr-2960	307	17	remain	remain	VERB
cblr-2960	307	18	compliant	compliant	ADJ
cblr-2960	307	19	with	with	ADP
cblr-2960	307	20	the	the	DET
cblr-2960	307	21	diversification	diversification	NOUN
cblr-2960	307	22	requirement	requirement	NOUN
cblr-2960	307	23	of	of	ADP
cblr-2960	307	24	section	section	NOUN
cblr-2960	307	25	817(h	817(h	PROPN
cblr-2960	307	26	)	)	PUNCT
cblr-2960	307	27	and	and	CCONJ
cblr-2960	307	28	the	the	DET
cblr-2960	307	29	investor	investor	NOUN
cblr-2960	307	30	control	control	NOUN
cblr-2960	307	31	doctrine.99	doctrine.99	VERB
cblr-2960	307	32	thus	thus	ADV
cblr-2960	307	33	,	,	PUNCT
cblr-2960	307	34	private	private	ADJ
cblr-2960	307	35	placement	placement	NOUN
cblr-2960	307	36	life	life	NOUN
cblr-2960	307	37	insurance	insurance	NOUN
cblr-2960	307	38	policies	policy	NOUN
cblr-2960	307	39	shielding	shield	VERB
cblr-2960	307	40	hedge	hedge	NOUN
cblr-2960	307	41	fund	fund	NOUN
cblr-2960	307	42	gains	gain	NOUN
cblr-2960	307	43	from	from	ADP
cblr-2960	307	44	taxes	taxis	NOUN
cblr-2960	307	45	remain	remain	VERB
cblr-2960	307	46	prominently	prominently	ADV
cblr-2960	307	47	available	available	ADJ
cblr-2960	307	48	.	.	PUNCT
cblr-2960	308	1	private	private	ADJ
cblr-2960	308	2	placement	placement	NOUN
cblr-2960	308	3	life	life	NOUN
cblr-2960	308	4	insurance	insurance	NOUN
cblr-2960	308	5	policies	policy	NOUN
cblr-2960	308	6	continue	continue	VERB
cblr-2960	308	7	to	to	PART
cblr-2960	308	8	be	be	AUX
cblr-2960	308	9	offered	offer	VERB
cblr-2960	308	10	by	by	ADP
cblr-2960	308	11	both	both	CCONJ
cblr-2960	308	12	domestic	domestic	ADJ
cblr-2960	308	13	and	and	CCONJ
cblr-2960	308	14	offshore	offshore	ADJ
cblr-2960	308	15	insurers	insurer	NOUN
cblr-2960	308	16	,	,	PUNCT
cblr-2960	308	17	including	include	VERB
cblr-2960	308	18	american	american	PROPN
cblr-2960	308	19	international	international	PROPN
cblr-2960	308	20	group	group	PROPN
cblr-2960	308	21	,	,	PUNCT
cblr-2960	308	22	inc	inc	PROPN
cblr-2960	308	23	.	.	PROPN
cblr-2960	308	24	,	,	PUNCT
cblr-2960	308	25	the	the	DET
cblr-2960	308	26	phoenix	phoenix	PROPN
cblr-2960	308	27	companies	company	NOUN
cblr-2960	308	28	,	,	PUNCT
cblr-2960	308	29	inc	inc	PROPN
cblr-2960	308	30	.	.	PROPN
cblr-2960	308	31	,	,	PUNCT
cblr-2960	308	32	sun	sun	NOUN
cblr-2960	308	33	life	life	PROPN
cblr-2960	308	34	financial	financial	PROPN
cblr-2960	308	35	,	,	PUNCT
cblr-2960	308	36	inc	inc	PROPN
cblr-2960	308	37	.	.	PROPN
cblr-2960	308	38	,	,	PUNCT
cblr-2960	308	39	and	and	CCONJ
cblr-2960	308	40	massachusetts	massachusetts	PROPN
cblr-2960	308	41	mutual	mutual	ADJ
cblr-2960	308	42	life	life	PROPN
cblr-2960	308	43	insurance	insurance	PROPN
cblr-2960	308	44	co.	co.	PROPN
cblr-2960	308	45	100	100	NUM
cblr-2960	308	46	despite	despite	SCONJ
cblr-2960	308	47	this	this	DET
cblr-2960	308	48	initial	initial	ADJ
cblr-2960	308	49	observation	observation	NOUN
cblr-2960	308	50	,	,	PUNCT
cblr-2960	308	51	further	further	ADJ
cblr-2960	308	52	analysis	analysis	NOUN
cblr-2960	308	53	illustrates	illustrate	VERB
cblr-2960	308	54	that	that	SCONJ
cblr-2960	308	55	the	the	DET
cblr-2960	308	56	recent	recent	ADJ
cblr-2960	308	57	changes	change	NOUN
cblr-2960	308	58	significantly	significantly	ADV
cblr-2960	308	59	increase	increase	VERB
cblr-2960	308	60	the	the	DET
cblr-2960	308	61	costs	cost	NOUN
cblr-2960	308	62	of	of	ADP
cblr-2960	308	63	such	such	ADJ
cblr-2960	308	64	transactions	transaction	NOUN
cblr-2960	308	65	.	.	PUNCT
cblr-2960	309	1	furthermore	furthermore	ADV
cblr-2960	309	2	,	,	PUNCT
cblr-2960	309	3	the	the	DET
cblr-2960	309	4	reforms	reform	NOUN
cblr-2960	309	5	have	have	AUX
cblr-2960	309	6	increased	increase	VERB
cblr-2960	309	7	constraints	constraint	NOUN
cblr-2960	309	8	on	on	ADP
cblr-2960	309	9	control	control	NOUN
cblr-2960	309	10	and	and	CCONJ
cblr-2960	309	11	the	the	DET
cblr-2960	309	12	need	need	NOUN
cblr-2960	309	13	for	for	ADP
cblr-2960	309	14	bothersome	bothersome	ADJ
cblr-2960	309	15	compliance	compliance	NOUN
cblr-2960	309	16	.	.	PUNCT
cblr-2960	309	17	'	'	PUNCT
cblr-2960	310	1	0	0	NUM
cblr-2960	310	2	'	'	PUNCT
cblr-2960	310	3	these	these	DET
cblr-2960	310	4	high	high	ADJ
cblr-2960	310	5	costs	cost	NOUN
cblr-2960	310	6	and	and	CCONJ
cblr-2960	310	7	increased	increase	VERB
cblr-2960	310	8	burdens	burden	NOUN
cblr-2960	310	9	are	be	AUX
cblr-2960	310	10	insurmountable	insurmountable	ADJ
cblr-2960	310	11	for	for	ADP
cblr-2960	310	12	most	most	ADJ
cblr-2960	310	13	investors	investor	NOUN
cblr-2960	310	14	,	,	PUNCT
cblr-2960	310	15	evidenced	evidence	VERB
cblr-2960	310	16	by	by	ADP
cblr-2960	310	17	a	a	DET
cblr-2960	310	18	small	small	ADJ
cblr-2960	310	19	market	market	NOUN
cblr-2960	310	20	share	share	NOUN
cblr-2960	310	21	of	of	ADP
cblr-2960	310	22	total	total	ADJ
cblr-2960	310	23	hedge	hedge	NOUN
cblr-2960	310	24	fund	fund	NOUN
cblr-2960	310	25	investment	investment	NOUN
cblr-2960	310	26	in	in	ADP
cblr-2960	310	27	private	private	ADJ
cblr-2960	310	28	placement	placement	NOUN
cblr-2960	310	29	life	life	NOUN
cblr-2960	310	30	insurance	insurance	NOUN
cblr-2960	310	31	contracts	contract	NOUN
cblr-2960	310	32	.	.	PUNCT
cblr-2960	311	1	02	02	NUM
cblr-2960	311	2	therefore	therefore	ADV
cblr-2960	311	3	,	,	PUNCT
cblr-2960	311	4	the	the	DET
cblr-2960	311	5	practical	practical	ADJ
cblr-2960	311	6	effects	effect	NOUN
cblr-2960	311	7	of	of	ADP
cblr-2960	311	8	the	the	DET
cblr-2960	311	9	reforms	reform	NOUN
cblr-2960	311	10	have	have	AUX
cblr-2960	311	11	been	be	AUX
cblr-2960	311	12	to	to	PART
cblr-2960	311	13	successfully	successfully	ADV
cblr-2960	311	14	deter	deter	VERB
cblr-2960	311	15	taxpayers	taxpayer	NOUN
cblr-2960	311	16	from	from	ADP
cblr-2960	311	17	using	use	VERB
cblr-2960	311	18	private	private	ADJ
cblr-2960	311	19	placement	placement	NOUN
cblr-2960	311	20	products	product	NOUN
cblr-2960	311	21	.	.	PUNCT
cblr-2960	311	22	"	"	PUNCT
cblr-2960	312	1	see	see	VERB
cblr-2960	312	2	neufeld	neufeld	PROPN
cblr-2960	312	3	,	,	PUNCT
cblr-2960	312	4	supra	supra	PROPN
cblr-2960	312	5	note	note	PROPN
cblr-2960	312	6	42	42	NUM
cblr-2960	312	7	,	,	PUNCT
cblr-2960	312	8	at	at	ADP
cblr-2960	312	9	1191	1191	NUM
cblr-2960	312	10	(	(	PUNCT
cblr-2960	312	11	noting	note	VERB
cblr-2960	312	12	that	that	SCONJ
cblr-2960	312	13	the	the	DET
cblr-2960	312	14	guidance	guidance	NOUN
cblr-2960	312	15	provided	provide	VERB
cblr-2960	312	16	by	by	ADP
cblr-2960	312	17	the	the	DET
cblr-2960	312	18	irs	irs	PROPN
cblr-2960	312	19	and	and	CCONJ
cblr-2960	312	20	treasury	treasury	PROPN
cblr-2960	312	21	allow	allow	VERB
cblr-2960	312	22	the	the	DET
cblr-2960	312	23	industry	industry	NOUN
cblr-2960	312	24	and	and	CCONJ
cblr-2960	312	25	investors	investor	NOUN
cblr-2960	312	26	to	to	PART
cblr-2960	312	27	proceed	proceed	VERB
cblr-2960	312	28	with	with	ADP
cblr-2960	312	29	variable	variable	ADJ
cblr-2960	312	30	life	life	NOUN
cblr-2960	312	31	insurance	insurance	NOUN
cblr-2960	312	32	programs	program	NOUN
cblr-2960	312	33	involving	involve	VERB
cblr-2960	312	34	hedge	hedge	NOUN
cblr-2960	312	35	funds	fund	NOUN
cblr-2960	312	36	more	more	ADV
cblr-2960	312	37	confidently	confidently	ADV
cblr-2960	312	38	than	than	ADP
cblr-2960	312	39	anytime	anytime	ADV
cblr-2960	312	40	in	in	ADP
cblr-2960	312	41	the	the	DET
cblr-2960	312	42	last	last	ADJ
cblr-2960	312	43	twenty	twenty	NUM
cblr-2960	312	44	years	year	NOUN
cblr-2960	312	45	)	)	PUNCT
cblr-2960	312	46	.	.	PUNCT
cblr-2960	313	1	"	"	PUNCT
cblr-2960	313	2	see	see	VERB
cblr-2960	313	3	supra	supra	PROPN
cblr-2960	313	4	part	part	PROPN
cblr-2960	313	5	iii	iii	PROPN
cblr-2960	313	6	.	.	PROPN
cblr-2960	313	7	100	100	NUM
cblr-2960	313	8	see	see	VERB
cblr-2960	313	9	silverman	silverman	NOUN
cblr-2960	313	10	,	,	PUNCT
cblr-2960	313	11	supra	supra	PROPN
cblr-2960	313	12	note	note	PROPN
cblr-2960	313	13	11	11	NUM
cblr-2960	313	14	;	;	PUNCT
cblr-2960	313	15	see	see	VERB
cblr-2960	313	16	also	also	ADV
cblr-2960	313	17	sun	sun	NOUN
cblr-2960	313	18	life	life	NOUN
cblr-2960	313	19	financial	financial	ADJ
cblr-2960	313	20	,	,	PUNCT
cblr-2960	313	21	variable	variable	ADJ
cblr-2960	313	22	universal	universal	ADJ
cblr-2960	313	23	life	life	NOUN
cblr-2960	313	24	insurance	insurance	NOUN
cblr-2960	313	25	,	,	PUNCT
cblr-2960	313	26	http://www.sunlife-usa.com/indiv/ind	http://www.sunlife-usa.com/indiv/ind	X
cblr-2960	313	27	11.cfm	11.cfm	PROPN
cblr-2960	313	28	(	(	PUNCT
cblr-2960	313	29	last	last	ADV
cblr-2960	313	30	visited	visit	VERB
cblr-2960	313	31	feb	feb	PROPN
cblr-2960	313	32	.	.	PROPN
cblr-2960	313	33	25	25	NUM
cblr-2960	313	34	,	,	PUNCT
cblr-2960	313	35	2008	2008	NUM
cblr-2960	313	36	)	)	PUNCT
cblr-2960	313	37	;	;	PUNCT
cblr-2960	313	38	the	the	DET
cblr-2960	313	39	phoenix	phoenix	PROPN
cblr-2960	313	40	companies	company	NOUN
cblr-2960	313	41	,	,	PUNCT
cblr-2960	313	42	inc	inc	PROPN
cblr-2960	313	43	.	.	PROPN
cblr-2960	313	44	,	,	PUNCT
cblr-2960	313	45	private	private	ADJ
cblr-2960	313	46	placement	placement	NOUN
cblr-2960	313	47	life	life	NOUN
cblr-2960	313	48	insurance	insurance	NOUN
cblr-2960	313	49	and	and	CCONJ
cblr-2960	313	50	annuities	annuity	NOUN
cblr-2960	313	51	,	,	PUNCT
cblr-2960	313	52	https://www.phoenixwm.phl.com/	https://www.phoenixwm.phl.com/	ADJ
cblr-2960	313	53	public	public	ADJ
cblr-2960	313	54	/	/	SYM
cblr-2960	313	55	products	product	NOUN
cblr-2960	313	56	/	/	SYM
cblr-2960	313	57	pp	pp	ADJ
cblr-2960	313	58	/	/	SYM
cblr-2960	313	59	index.jsp	index.jsp	PROPN
cblr-2960	313	60	(	(	PUNCT
cblr-2960	313	61	last	last	ADJ
cblr-2960	313	62	visited	visit	VERB
cblr-2960	313	63	feb	feb	PROPN
cblr-2960	313	64	.	.	PROPN
cblr-2960	313	65	25	25	NUM
cblr-2960	313	66	,	,	PUNCT
cblr-2960	313	67	2008	2008	NUM
cblr-2960	313	68	)	)	PUNCT
cblr-2960	313	69	.	.	PUNCT
cblr-2960	314	1	101	101	NUM
cblr-2960	314	2	see	see	VERB
cblr-2960	314	3	infra	infra	NOUN
cblr-2960	314	4	part	part	NOUN
cblr-2960	314	5	v.a	v.a	PROPN
cblr-2960	314	6	.	.	PROPN
cblr-2960	314	7	102	102	NUM
cblr-2960	314	8	see	see	NOUN
cblr-2960	314	9	infra	infra	NOUN
cblr-2960	314	10	part	part	NOUN
cblr-2960	314	11	v.b	v.b	PROPN
cblr-2960	314	12	.	.	PUNCT
cblr-2960	315	1	[	[	X
cblr-2960	315	2	vol	vol	NOUN
cblr-2960	315	3	.	.	NOUN
cblr-2960	315	4	2008	2008	NUM
cblr-2960	315	5	a.	a.	NOUN
cblr-2960	315	6	having	have	VERB
cblr-2960	315	7	to	to	PART
cblr-2960	315	8	follow	follow	VERB
cblr-2960	315	9	the	the	DET
cblr-2960	315	10	rules	rule	NOUN
cblr-2960	315	11	1	1	NUM
cblr-2960	315	12	.	.	PUNCT
cblr-2960	315	13	loss	loss	NOUN
cblr-2960	315	14	of	of	ADP
cblr-2960	315	15	control	control	NOUN
cblr-2960	315	16	the	the	DET
cblr-2960	315	17	loss	loss	NOUN
cblr-2960	315	18	of	of	ADP
cblr-2960	315	19	control	control	NOUN
cblr-2960	315	20	caused	cause	VERB
cblr-2960	315	21	by	by	ADP
cblr-2960	315	22	the	the	DET
cblr-2960	315	23	first	first	ADJ
cblr-2960	315	24	prong	prong	NOUN
cblr-2960	315	25	of	of	ADP
cblr-2960	315	26	the	the	DET
cblr-2960	315	27	investor	investor	NOUN
cblr-2960	315	28	control	control	NOUN
cblr-2960	315	29	doctrine	doctrine	NOUN
cblr-2960	315	30	increases	increase	VERB
cblr-2960	315	31	effective	effective	ADJ
cblr-2960	315	32	frictions	friction	NOUN
cblr-2960	315	33	and	and	CCONJ
cblr-2960	315	34	efficiently	efficiently	ADV
cblr-2960	315	35	reduces	reduce	VERB
cblr-2960	315	36	the	the	DET
cblr-2960	315	37	taxpayer	taxpayer	NOUN
cblr-2960	315	38	's	's	PART
cblr-2960	315	39	elasticity	elasticity	NOUN
cblr-2960	315	40	of	of	ADP
cblr-2960	315	41	taxable	taxable	ADJ
cblr-2960	315	42	income	income	NOUN
cblr-2960	315	43	.	.	PUNCT
cblr-2960	316	1	while	while	SCONJ
cblr-2960	316	2	practitioners	practitioner	NOUN
cblr-2960	316	3	and	and	CCONJ
cblr-2960	316	4	life	life	NOUN
cblr-2960	316	5	insurance	insurance	NOUN
cblr-2960	316	6	companies	company	NOUN
cblr-2960	316	7	are	be	AUX
cblr-2960	316	8	still	still	ADV
cblr-2960	316	9	able	able	ADJ
cblr-2960	316	10	to	to	PART
cblr-2960	316	11	structure	structure	VERB
cblr-2960	316	12	policies	policy	NOUN
cblr-2960	316	13	as	as	ADP
cblr-2960	316	14	a	a	DET
cblr-2960	316	15	tax	tax	NOUN
cblr-2960	316	16	avoidance	avoidance	NOUN
cblr-2960	316	17	mechanism	mechanism	NOUN
cblr-2960	316	18	,	,	PUNCT
cblr-2960	316	19	the	the	DET
cblr-2960	316	20	investor	investor	NOUN
cblr-2960	316	21	control	control	NOUN
cblr-2960	316	22	doctrine	doctrine	NOUN
cblr-2960	316	23	deters	deter	VERB
cblr-2960	316	24	investors	investor	NOUN
cblr-2960	316	25	who	who	PRON
cblr-2960	316	26	prefer	prefer	VERB
cblr-2960	316	27	direct	direct	ADJ
cblr-2960	316	28	involvement	involvement	NOUN
cblr-2960	316	29	with	with	ADP
cblr-2960	316	30	the	the	DET
cblr-2960	316	31	policy	policy	NOUN
cblr-2960	316	32	's	's	PART
cblr-2960	316	33	underlying	underlie	VERB
cblr-2960	316	34	investments	investment	NOUN
cblr-2960	316	35	.	.	PUNCT
cblr-2960	317	1	policyholders	policyholder	NOUN
cblr-2960	317	2	lose	lose	VERB
cblr-2960	317	3	a	a	DET
cblr-2960	317	4	substantial	substantial	ADJ
cblr-2960	317	5	amount	amount	NOUN
cblr-2960	317	6	of	of	ADP
cblr-2960	317	7	control	control	NOUN
cblr-2960	317	8	by	by	ADP
cblr-2960	317	9	purchasing	purchase	VERB
cblr-2960	317	10	a	a	DET
cblr-2960	317	11	private	private	ADJ
cblr-2960	317	12	placement	placement	NOUN
cblr-2960	317	13	life	life	NOUN
cblr-2960	317	14	insurance	insurance	NOUN
cblr-2960	317	15	contract	contract	NOUN
cblr-2960	317	16	instead	instead	ADV
cblr-2960	317	17	of	of	ADP
cblr-2960	317	18	directly	directly	ADV
cblr-2960	317	19	investing	invest	VERB
cblr-2960	317	20	in	in	ADP
cblr-2960	317	21	a	a	DET
cblr-2960	317	22	hedge	hedge	NOUN
cblr-2960	317	23	fund	fund	NOUN
cblr-2960	317	24	.	.	PUNCT
cblr-2960	318	1	when	when	SCONJ
cblr-2960	318	2	investing	invest	VERB
cblr-2960	318	3	directly	directly	ADV
cblr-2960	318	4	into	into	ADP
cblr-2960	318	5	a	a	DET
cblr-2960	318	6	hedge	hedge	NOUN
cblr-2960	318	7	fund	fund	NOUN
cblr-2960	318	8	,	,	PUNCT
cblr-2960	318	9	the	the	DET
cblr-2960	318	10	investor	investor	NOUN
cblr-2960	318	11	may	may	AUX
cblr-2960	318	12	assert	assert	VERB
cblr-2960	318	13	actual	actual	ADJ
cblr-2960	318	14	control	control	NOUN
cblr-2960	318	15	over	over	ADP
cblr-2960	318	16	the	the	DET
cblr-2960	318	17	investment	investment	NOUN
cblr-2960	318	18	decisions	decision	NOUN
cblr-2960	318	19	of	of	ADP
cblr-2960	318	20	the	the	DET
cblr-2960	318	21	subaccounts	subaccount	NOUN
cblr-2960	318	22	.	.	PUNCT
cblr-2960	319	1	°	°	ADP
cblr-2960	319	2	3	3	NUM
cblr-2960	319	3	with	with	ADP
cblr-2960	319	4	direct	direct	ADJ
cblr-2960	319	5	investments	investment	NOUN
cblr-2960	319	6	,	,	PUNCT
cblr-2960	319	7	the	the	DET
cblr-2960	319	8	investor	investor	NOUN
cblr-2960	319	9	can	can	AUX
cblr-2960	319	10	hire	hire	VERB
cblr-2960	319	11	a	a	DET
cblr-2960	319	12	single	single	ADJ
cblr-2960	319	13	hedge	hedge	NOUN
cblr-2960	319	14	fund	fund	NOUN
cblr-2960	319	15	manager	manager	NOUN
cblr-2960	319	16	or	or	CCONJ
cblr-2960	319	17	a	a	DET
cblr-2960	319	18	combination	combination	NOUN
cblr-2960	319	19	of	of	ADP
cblr-2960	319	20	hedge	hedge	NOUN
cblr-2960	319	21	fund	fund	NOUN
cblr-2960	319	22	managers	manager	NOUN
cblr-2960	319	23	to	to	PART
cblr-2960	319	24	tailor	tailor	VERB
cblr-2960	319	25	the	the	DET
cblr-2960	319	26	portfolio	portfolio	NOUN
cblr-2960	319	27	to	to	ADP
cblr-2960	319	28	the	the	DET
cblr-2960	319	29	investor	investor	NOUN
cblr-2960	319	30	's	's	PART
cblr-2960	319	31	needs	need	NOUN
cblr-2960	319	32	and	and	CCONJ
cblr-2960	319	33	desires	desire	NOUN
cblr-2960	319	34	.	.	PUNCT
cblr-2960	319	35	'	'	PUNCT
cblr-2960	320	1	however	however	ADV
cblr-2960	320	2	,	,	PUNCT
cblr-2960	320	3	in	in	ADP
cblr-2960	320	4	an	an	DET
cblr-2960	320	5	insurance	insurance	NOUN
cblr-2960	320	6	-	-	PUNCT
cblr-2960	320	7	dedicated	dedicate	VERB
cblr-2960	320	8	fund	fund	NOUN
cblr-2960	320	9	,	,	PUNCT
cblr-2960	320	10	because	because	SCONJ
cblr-2960	320	11	the	the	DET
cblr-2960	320	12	investor	investor	NOUN
cblr-2960	320	13	's	's	PART
cblr-2960	320	14	assets	asset	NOUN
cblr-2960	320	15	are	be	AUX
cblr-2960	320	16	pooled	pool	VERB
cblr-2960	320	17	with	with	ADP
cblr-2960	320	18	those	those	PRON
cblr-2960	320	19	of	of	ADP
cblr-2960	320	20	many	many	ADJ
cblr-2960	320	21	other	other	ADJ
cblr-2960	320	22	policyholders	policyholder	NOUN
cblr-2960	320	23	,	,	PUNCT
cblr-2960	320	24	managers	manager	NOUN
cblr-2960	320	25	of	of	ADP
cblr-2960	320	26	funds	fund	NOUN
cblr-2960	320	27	can	can	AUX
cblr-2960	320	28	not	not	PART
cblr-2960	320	29	offer	offer	VERB
cblr-2960	320	30	any	any	DET
cblr-2960	320	31	alteration	alteration	NOUN
cblr-2960	320	32	to	to	ADP
cblr-2960	320	33	their	their	PRON
cblr-2960	320	34	product	product	NOUN
cblr-2960	320	35	in	in	ADP
cblr-2960	320	36	order	order	NOUN
cblr-2960	320	37	to	to	PART
cblr-2960	320	38	accommodate	accommodate	VERB
cblr-2960	320	39	individual	individual	ADJ
cblr-2960	320	40	needs	need	NOUN
cblr-2960	320	41	.	.	PUNCT
cblr-2960	321	1	'015	'015	PROPN
cblr-2960	321	2	consequently	consequently	ADV
cblr-2960	321	3	,	,	PUNCT
cblr-2960	321	4	an	an	DET
cblr-2960	321	5	investor	investor	NOUN
cblr-2960	321	6	who	who	PRON
cblr-2960	321	7	does	do	AUX
cblr-2960	321	8	not	not	PART
cblr-2960	321	9	approve	approve	VERB
cblr-2960	321	10	of	of	ADP
cblr-2960	321	11	a	a	DET
cblr-2960	321	12	certain	certain	ADJ
cblr-2960	321	13	strategy	strategy	NOUN
cblr-2960	321	14	is	be	AUX
cblr-2960	321	15	powerless	powerless	ADJ
cblr-2960	321	16	to	to	PART
cblr-2960	321	17	change	change	VERB
cblr-2960	321	18	that	that	DET
cblr-2960	321	19	allocation	allocation	NOUN
cblr-2960	321	20	,	,	PUNCT
cblr-2960	321	21	short	short	ADJ
cblr-2960	321	22	of	of	ADP
cblr-2960	321	23	bailing	bail	VERB
cblr-2960	321	24	out	out	ADP
cblr-2960	321	25	of	of	ADP
cblr-2960	321	26	the	the	DET
cblr-2960	321	27	fund	fund	NOUN
cblr-2960	321	28	altogether.0	altogether.0	PROPN
cblr-2960	321	29	°	°	PRON
cblr-2960	321	30	thus	thus	ADV
cblr-2960	321	31	,	,	PUNCT
cblr-2960	321	32	investing	invest	VERB
cblr-2960	321	33	through	through	ADP
cblr-2960	321	34	a	a	DET
cblr-2960	321	35	private	private	ADJ
cblr-2960	321	36	placement	placement	NOUN
cblr-2960	321	37	life	life	NOUN
cblr-2960	321	38	insurance	insurance	NOUN
cblr-2960	321	39	policy	policy	NOUN
cblr-2960	321	40	signifies	signify	VERB
cblr-2960	321	41	the	the	DET
cblr-2960	321	42	giving	give	VERB
cblr-2960	321	43	103	103	NUM
cblr-2960	321	44	lhabitant	lhabitant	ADJ
cblr-2960	321	45	,	,	PUNCT
cblr-2960	321	46	supra	supra	PROPN
cblr-2960	321	47	note	note	PROPN
cblr-2960	321	48	1	1	NUM
cblr-2960	321	49	,	,	PUNCT
cblr-2960	321	50	at	at	ADP
cblr-2960	321	51	515	515	NUM
cblr-2960	321	52	.	.	PUNCT
cblr-2960	322	1	"	"	PUNCT
cblr-2960	322	2	'	'	PUNCT
cblr-2960	322	3	i	i	PRON
cblr-2960	322	4	d.	d.	PROPN
cblr-2960	322	5	(	(	PUNCT
cblr-2960	322	6	noting	note	VERB
cblr-2960	322	7	that	that	SCONJ
cblr-2960	322	8	to	to	PART
cblr-2960	322	9	determine	determine	VERB
cblr-2960	322	10	an	an	DET
cblr-2960	322	11	optimal	optimal	ADJ
cblr-2960	322	12	portfolio	portfolio	NOUN
cblr-2960	322	13	for	for	ADP
cblr-2960	322	14	each	each	DET
cblr-2960	322	15	investor	investor	NOUN
cblr-2960	322	16	,	,	PUNCT
cblr-2960	322	17	"	"	PUNCT
cblr-2960	322	18	it	it	PRON
cblr-2960	322	19	is	be	AUX
cblr-2960	322	20	necessary	necessary	ADJ
cblr-2960	322	21	to	to	PART
cblr-2960	322	22	take	take	VERB
cblr-2960	322	23	into	into	ADP
cblr-2960	322	24	account	account	NOUN
cblr-2960	322	25	the	the	DET
cblr-2960	322	26	investor	investor	NOUN
cblr-2960	322	27	's	's	PART
cblr-2960	322	28	time	time	NOUN
cblr-2960	322	29	horizon	horizon	PROPN
cblr-2960	322	30	,	,	PUNCT
cblr-2960	322	31	his	his	PRON
cblr-2960	322	32	risk	risk	NOUN
cblr-2960	322	33	appetite	appetite	NOUN
cblr-2960	322	34	,	,	PUNCT
cblr-2960	322	35	his	his	PRON
cblr-2960	322	36	overall	overall	ADJ
cblr-2960	322	37	objectives	objective	NOUN
cblr-2960	322	38	,	,	PUNCT
cblr-2960	322	39	his	his	PRON
cblr-2960	322	40	age	age	NOUN
cblr-2960	322	41	,	,	PUNCT
cblr-2960	322	42	his	his	PRON
cblr-2960	322	43	available	available	ADJ
cblr-2960	322	44	income	income	NOUN
cblr-2960	322	45	and	and	CCONJ
cblr-2960	322	46	the	the	DET
cblr-2960	322	47	rest	rest	NOUN
cblr-2960	322	48	of	of	ADP
cblr-2960	322	49	the	the	DET
cblr-2960	322	50	assets	asset	NOUN
cblr-2960	322	51	of	of	ADP
cblr-2960	322	52	his	his	PRON
cblr-2960	322	53	portfolio	portfolio	NOUN
cblr-2960	322	54	(	(	PUNCT
cblr-2960	322	55	including	include	VERB
cblr-2960	322	56	,	,	PUNCT
cblr-2960	322	57	if	if	SCONJ
cblr-2960	322	58	relevant	relevant	ADJ
cblr-2960	322	59	,	,	PUNCT
cblr-2960	322	60	his	his	PRON
cblr-2960	322	61	liabilities	liability	NOUN
cblr-2960	322	62	,	,	PUNCT
cblr-2960	322	63	as	as	ADV
cblr-2960	322	64	well	well	ADV
cblr-2960	322	65	as	as	ADP
cblr-2960	322	66	any	any	DET
cblr-2960	322	67	constraints	constraint	NOUN
cblr-2960	322	68	,	,	PUNCT
cblr-2960	322	69	tax	tax	NOUN
cblr-2960	322	70	status	status	NOUN
cblr-2960	322	71	,	,	PUNCT
cblr-2960	322	72	etc	etc	X
cblr-2960	322	73	.	.	X
cblr-2960	322	74	)	)	PUNCT
cblr-2960	322	75	"	"	PUNCT
cblr-2960	322	76	)	)	PUNCT
cblr-2960	322	77	.	.	PUNCT
cblr-2960	323	1	1o	1o	NUM
cblr-2960	323	2	'	'	PART
cblr-2960	323	3	i	i	PRON
cblr-2960	323	4	d.	d.	PROPN
cblr-2960	323	5	at	at	ADP
cblr-2960	323	6	516	516	NUM
cblr-2960	323	7	(	(	PUNCT
cblr-2960	323	8	explaining	explain	VERB
cblr-2960	323	9	that	that	SCONJ
cblr-2960	323	10	a	a	DET
cblr-2960	323	11	drawback	drawback	NOUN
cblr-2960	323	12	of	of	ADP
cblr-2960	323	13	funds	fund	NOUN
cblr-2960	323	14	of	of	ADP
cblr-2960	323	15	funds	fund	NOUN
cblr-2960	323	16	from	from	ADP
cblr-2960	323	17	the	the	DET
cblr-2960	323	18	investor	investor	NOUN
cblr-2960	323	19	's	's	PART
cblr-2960	323	20	perspective	perspective	NOUN
cblr-2960	323	21	is	be	AUX
cblr-2960	323	22	the	the	DET
cblr-2960	323	23	lack	lack	NOUN
cblr-2960	323	24	of	of	ADP
cblr-2960	323	25	control	control	NOUN
cblr-2960	323	26	)	)	PUNCT
cblr-2960	323	27	.	.	PUNCT
cblr-2960	324	1	106	106	NUM
cblr-2960	325	1	i	i	PRON
cblr-2960	325	2	d.	d.	NOUN
cblr-2960	325	3	at	at	ADP
cblr-2960	325	4	587	587	NUM
cblr-2960	325	5	.	.	PUNCT
cblr-2960	326	1	no	no	INTJ
cblr-2960	326	2	.	.	PUNCT
cblr-2960	327	1	2:6941	2:6941	NUM
cblr-2960	327	2	job	job	NOUN
cblr-2960	327	3	well	well	ADV
cblr-2960	327	4	done	do	VERB
cblr-2960	327	5	columbia	columbia	PROPN
cblr-2960	327	6	business	business	NOUN
cblr-2960	327	7	law	law	PROPN
cblr-2960	327	8	review	review	VERB
cblr-2960	327	9	up	up	ADP
cblr-2960	327	10	of	of	ADP
cblr-2960	327	11	a	a	DET
cblr-2960	327	12	good	good	ADJ
cblr-2960	327	13	deal	deal	NOUN
cblr-2960	327	14	of	of	ADP
cblr-2960	327	15	control	control	NOUN
cblr-2960	327	16	and	and	CCONJ
cblr-2960	327	17	choice	choice	NOUN
cblr-2960	327	18	over	over	ADP
cblr-2960	327	19	investments	investment	NOUN
cblr-2960	327	20	in	in	ADP
cblr-2960	327	21	order	order	NOUN
cblr-2960	327	22	to	to	PART
cblr-2960	327	23	satisfy	satisfy	VERB
cblr-2960	327	24	relevant	relevant	ADJ
cblr-2960	327	25	tax	tax	NOUN
cblr-2960	327	26	rules	rule	NOUN
cblr-2960	327	27	.	.	PUNCT
cblr-2960	328	1	"7	"7	ADJ
cblr-2960	328	2	in	in	ADP
cblr-2960	328	3	effect	effect	NOUN
cblr-2960	328	4	,	,	PUNCT
cblr-2960	328	5	the	the	DET
cblr-2960	328	6	friction	friction	NOUN
cblr-2960	328	7	of	of	ADP
cblr-2960	328	8	relinquishing	relinquish	VERB
cblr-2960	328	9	control	control	NOUN
cblr-2960	328	10	is	be	AUX
cblr-2960	328	11	very	very	ADV
cblr-2960	328	12	strong	strong	ADJ
cblr-2960	328	13	.	.	PUNCT
cblr-2960	329	1	the	the	DET
cblr-2960	329	2	loss	loss	NOUN
cblr-2960	329	3	of	of	ADP
cblr-2960	329	4	control	control	NOUN
cblr-2960	329	5	over	over	ADP
cblr-2960	329	6	underlying	underlie	VERB
cblr-2960	329	7	investments	investment	NOUN
cblr-2960	329	8	is	be	AUX
cblr-2960	329	9	a	a	DET
cblr-2960	329	10	substantial	substantial	ADJ
cblr-2960	329	11	inconvenience	inconvenience	NOUN
cblr-2960	329	12	to	to	ADP
cblr-2960	329	13	sophisticated	sophisticated	ADJ
cblr-2960	329	14	investors	investor	NOUN
cblr-2960	329	15	who	who	PRON
cblr-2960	329	16	often	often	ADV
cblr-2960	329	17	have	have	VERB
cblr-2960	329	18	the	the	DET
cblr-2960	329	19	knowledge	knowledge	NOUN
cblr-2960	329	20	and	and	CCONJ
cblr-2960	329	21	competence	competence	NOUN
cblr-2960	329	22	to	to	PART
cblr-2960	329	23	make	make	VERB
cblr-2960	329	24	direct	direct	ADJ
cblr-2960	329	25	investment	investment	NOUN
cblr-2960	329	26	decisions	decision	NOUN
cblr-2960	329	27	.	.	PUNCT
cblr-2960	330	1	with	with	ADP
cblr-2960	330	2	the	the	DET
cblr-2960	330	3	exception	exception	NOUN
cblr-2960	330	4	that	that	SCONJ
cblr-2960	330	5	there	there	PRON
cblr-2960	330	6	will	will	AUX
cblr-2960	330	7	be	be	AUX
cblr-2960	330	8	cash	cash	NOUN
cblr-2960	330	9	accumulation	accumulation	NOUN
cblr-2960	330	10	deferral	deferral	NOUN
cblr-2960	330	11	if	if	SCONJ
cblr-2960	330	12	the	the	DET
cblr-2960	330	13	investor	investor	NOUN
cblr-2960	330	14	can	can	AUX
cblr-2960	330	15	keep	keep	VERB
cblr-2960	330	16	his	his	PRON
cblr-2960	330	17	hands	hand	NOUN
cblr-2960	330	18	off	off	ADP
cblr-2960	330	19	,	,	PUNCT
cblr-2960	330	20	the	the	DET
cblr-2960	330	21	reforms	reform	NOUN
cblr-2960	330	22	shut	shut	VERB
cblr-2960	330	23	down	down	ADP
cblr-2960	330	24	the	the	DET
cblr-2960	330	25	use	use	NOUN
cblr-2960	330	26	of	of	ADP
cblr-2960	330	27	private	private	ADJ
cblr-2960	330	28	placement	placement	NOUN
cblr-2960	330	29	life	life	NOUN
cblr-2960	330	30	insurance	insurance	NOUN
cblr-2960	330	31	wrappers	wrapper	NOUN
cblr-2960	330	32	if	if	SCONJ
cblr-2960	330	33	the	the	DET
cblr-2960	330	34	investor	investor	NOUN
cblr-2960	330	35	exerts	exert	VERB
cblr-2960	330	36	too	too	ADV
cblr-2960	330	37	much	much	ADJ
cblr-2960	330	38	control.108	control.108	NOUN
cblr-2960	330	39	in	in	ADP
cblr-2960	330	40	addition	addition	NOUN
cblr-2960	330	41	,	,	PUNCT
cblr-2960	330	42	the	the	DET
cblr-2960	330	43	loss	loss	NOUN
cblr-2960	330	44	of	of	ADP
cblr-2960	330	45	control	control	NOUN
cblr-2960	330	46	is	be	AUX
cblr-2960	330	47	a	a	DET
cblr-2960	330	48	rigid	rigid	ADJ
cblr-2960	330	49	friction	friction	NOUN
cblr-2960	330	50	,	,	PUNCT
cblr-2960	330	51	forcing	force	VERB
cblr-2960	330	52	investors	investor	NOUN
cblr-2960	330	53	to	to	AUX
cblr-2960	330	54	either	either	CCONJ
cblr-2960	330	55	relinquish	relinquish	VERB
cblr-2960	330	56	control	control	NOUN
cblr-2960	330	57	or	or	CCONJ
cblr-2960	330	58	to	to	PART
cblr-2960	330	59	refrain	refrain	VERB
cblr-2960	330	60	from	from	ADP
cblr-2960	330	61	investing	invest	VERB
cblr-2960	330	62	in	in	ADP
cblr-2960	330	63	hedge	hedge	NOUN
cblr-2960	330	64	funds	fund	NOUN
cblr-2960	330	65	using	use	VERB
cblr-2960	330	66	life	life	NOUN
cblr-2960	330	67	insurance	insurance	NOUN
cblr-2960	330	68	products	product	NOUN
cblr-2960	330	69	.	.	PUNCT
cblr-2960	331	1	the	the	DET
cblr-2960	331	2	taxpayer	taxpayer	NOUN
cblr-2960	331	3	can	can	AUX
cblr-2960	331	4	not	not	PART
cblr-2960	331	5	make	make	VERB
cblr-2960	331	6	any	any	DET
cblr-2960	331	7	alteration	alteration	NOUN
cblr-2960	331	8	to	to	ADP
cblr-2960	331	9	the	the	DET
cblr-2960	331	10	deal	deal	NOUN
cblr-2960	331	11	to	to	PART
cblr-2960	331	12	sidestep	sidestep	VERB
cblr-2960	331	13	the	the	DET
cblr-2960	331	14	first	first	ADJ
cblr-2960	331	15	prong	prong	NOUN
cblr-2960	331	16	of	of	ADP
cblr-2960	331	17	the	the	DET
cblr-2960	331	18	investor	investor	NOUN
cblr-2960	331	19	control	control	NOUN
cblr-2960	331	20	doctrine.109	doctrine.109	VERB
cblr-2960	331	21	similarly	similarly	ADV
cblr-2960	331	22	,	,	PUNCT
cblr-2960	331	23	the	the	DET
cblr-2960	331	24	loss	loss	NOUN
cblr-2960	331	25	of	of	ADP
cblr-2960	331	26	control	control	NOUN
cblr-2960	331	27	reduces	reduce	VERB
cblr-2960	331	28	the	the	DET
cblr-2960	331	29	taxpayer	taxpayer	NOUN
cblr-2960	331	30	's	's	PART
cblr-2960	331	31	elasticity	elasticity	NOUN
cblr-2960	331	32	of	of	ADP
cblr-2960	331	33	taxable	taxable	ADJ
cblr-2960	331	34	income	income	NOUN
cblr-2960	331	35	.	.	PUNCT
cblr-2960	332	1	if	if	SCONJ
cblr-2960	332	2	the	the	DET
cblr-2960	332	3	taxpayer	taxpayer	NOUN
cblr-2960	332	4	desires	desire	NOUN
cblr-2960	332	5	to	to	PART
cblr-2960	332	6	direct	direct	VERB
cblr-2960	332	7	investments	investment	NOUN
cblr-2960	332	8	in	in	ADP
cblr-2960	332	9	the	the	DET
cblr-2960	332	10	sub	sub	NOUN
cblr-2960	332	11	-	-	NOUN
cblr-2960	332	12	accounts	account	NOUN
cblr-2960	332	13	,	,	PUNCT
cblr-2960	332	14	the	the	DET
cblr-2960	332	15	policyholder	policyholder	NOUN
cblr-2960	332	16	must	must	AUX
cblr-2960	332	17	abandon	abandon	VERB
cblr-2960	332	18	all	all	DET
cblr-2960	332	19	private	private	ADJ
cblr-2960	332	20	placement	placement	NOUN
cblr-2960	332	21	life	life	NOUN
cblr-2960	332	22	insurance	insurance	NOUN
cblr-2960	332	23	products	product	NOUN
cblr-2960	332	24	in	in	ADP
cblr-2960	332	25	order	order	NOUN
cblr-2960	332	26	to	to	PART
cblr-2960	332	27	do	do	AUX
cblr-2960	332	28	so	so	ADV
cblr-2960	332	29	.	.	PUNCT
cblr-2960	333	1	the	the	DET
cblr-2960	333	2	reforms	reform	NOUN
cblr-2960	333	3	make	make	VERB
cblr-2960	333	4	it	it	PRON
cblr-2960	333	5	impossible	impossible	ADJ
cblr-2960	333	6	for	for	SCONJ
cblr-2960	333	7	an	an	DET
cblr-2960	333	8	investor	investor	NOUN
cblr-2960	333	9	to	to	PART
cblr-2960	333	10	maintain	maintain	VERB
cblr-2960	333	11	the	the	DET
cblr-2960	333	12	power	power	NOUN
cblr-2960	333	13	to	to	PART
cblr-2960	333	14	make	make	VERB
cblr-2960	333	15	investment	investment	NOUN
cblr-2960	333	16	decisions	decision	NOUN
cblr-2960	333	17	or	or	CCONJ
cblr-2960	333	18	premium	premium	NOUN
cblr-2960	333	19	allocations	allocation	NOUN
cblr-2960	333	20	and	and	CCONJ
cblr-2960	333	21	use	use	VERB
cblr-2960	333	22	insurance	insurance	NOUN
cblr-2960	333	23	wrappers	wrapper	NOUN
cblr-2960	333	24	as	as	ADP
cblr-2960	333	25	a	a	DET
cblr-2960	333	26	tax	tax	NOUN
cblr-2960	333	27	planning	planning	NOUN
cblr-2960	333	28	mechanism	mechanism	NOUN
cblr-2960	333	29	.	.	PUNCT
cblr-2960	334	1	the	the	DET
cblr-2960	334	2	investor	investor	NOUN
cblr-2960	334	3	must	must	AUX
cblr-2960	334	4	choose	choose	VERB
cblr-2960	334	5	between	between	ADP
cblr-2960	334	6	investment	investment	NOUN
cblr-2960	334	7	control	control	NOUN
cblr-2960	334	8	and	and	CCONJ
cblr-2960	334	9	the	the	DET
cblr-2960	334	10	tax	tax	NOUN
cblr-2960	334	11	benefit	benefit	NOUN
cblr-2960	334	12	.	.	PUNCT
cblr-2960	335	1	thus	thus	ADV
cblr-2960	335	2	,	,	PUNCT
cblr-2960	335	3	the	the	DET
cblr-2960	335	4	loss	loss	NOUN
cblr-2960	335	5	of	of	ADP
cblr-2960	335	6	control	control	NOUN
cblr-2960	335	7	both	both	PRON
cblr-2960	335	8	increases	increase	VERB
cblr-2960	335	9	frictions	friction	NOUN
cblr-2960	335	10	and	and	CCONJ
cblr-2960	335	11	reduces	reduce	VERB
cblr-2960	335	12	the	the	DET
cblr-2960	335	13	elasticity	elasticity	NOUN
cblr-2960	335	14	of	of	ADP
cblr-2960	335	15	taxable	taxable	ADJ
cblr-2960	335	16	income	income	NOUN
cblr-2960	335	17	,	,	PUNCT
cblr-2960	335	18	indicating	indicate	VERB
cblr-2960	335	19	that	that	SCONJ
cblr-2960	335	20	the	the	DET
cblr-2960	335	21	tax	tax	NOUN
cblr-2960	335	22	reforms	reform	NOUN
cblr-2960	335	23	have	have	AUX
cblr-2960	335	24	been	be	AUX
cblr-2960	335	25	efficient	efficient	ADJ
cblr-2960	335	26	.	.	PUNCT
cblr-2960	336	1	2	2	X
cblr-2960	336	2	.	.	X
cblr-2960	336	3	reluctance	reluctance	NOUN
cblr-2960	336	4	the	the	DET
cblr-2960	336	5	diversification	diversification	NOUN
cblr-2960	336	6	requirement	requirement	NOUN
cblr-2960	336	7	of	of	ADP
cblr-2960	336	8	section	section	NOUN
cblr-2960	336	9	817(h	817(h	PROPN
cblr-2960	336	10	)	)	PUNCT
cblr-2960	336	11	and	and	CCONJ
cblr-2960	336	12	the	the	DET
cblr-2960	336	13	regulations	regulation	NOUN
cblr-2960	336	14	under	under	ADP
cblr-2960	336	15	the	the	DET
cblr-2960	336	16	look	look	VERB
cblr-2960	336	17	-	-	PUNCT
cblr-2960	336	18	through	through	ADP
cblr-2960	336	19	doctrine	doctrine	NOUN
cblr-2960	336	20	increase	increase	NOUN
cblr-2960	336	21	frictions	friction	NOUN
cblr-2960	336	22	against	against	ADP
cblr-2960	336	23	tax	tax	NOUN
cblr-2960	336	24	accommodation	accommodation	NOUN
cblr-2960	336	25	parties	party	NOUN
cblr-2960	336	26	like	like	ADP
cblr-2960	336	27	insurance	insurance	NOUN
cblr-2960	336	28	companies	company	NOUN
cblr-2960	336	29	and	and	CCONJ
cblr-2960	336	30	hedge	hedge	NOUN
cblr-2960	336	31	funds	fund	NOUN
cblr-2960	336	32	,	,	PUNCT
cblr-2960	336	33	making	make	VERB
cblr-2960	336	34	it	it	PRON
cblr-2960	336	35	more	more	ADV
cblr-2960	336	36	difficult	difficult	ADJ
cblr-2960	336	37	for	for	ADP
cblr-2960	336	38	107	107	NUM
cblr-2960	336	39	see	see	NOUN
cblr-2960	336	40	silverman	silverman	NOUN
cblr-2960	336	41	,	,	PUNCT
cblr-2960	336	42	supra	supra	PROPN
cblr-2960	336	43	note	note	PROPN
cblr-2960	336	44	11	11	NUM
cblr-2960	336	45	(	(	PUNCT
cblr-2960	336	46	indicating	indicate	VERB
cblr-2960	336	47	that	that	SCONJ
cblr-2960	336	48	wealthy	wealthy	ADJ
cblr-2960	336	49	investors	investor	NOUN
cblr-2960	336	50	must	must	AUX
cblr-2960	336	51	give	give	VERB
cblr-2960	336	52	up	up	ADP
cblr-2960	336	53	control	control	NOUN
cblr-2960	336	54	over	over	ADP
cblr-2960	336	55	their	their	PRON
cblr-2960	336	56	investments	investment	NOUN
cblr-2960	336	57	)	)	PUNCT
cblr-2960	336	58	.	.	PUNCT
cblr-2960	337	1	108	108	NUM
cblr-2960	337	2	see	see	VERB
cblr-2960	337	3	rev	rev	PROPN
cblr-2960	337	4	.	.	PROPN
cblr-2960	337	5	rul	rul	PROPN
cblr-2960	337	6	.	.	PUNCT
cblr-2960	337	7	2003	2003	NUM
cblr-2960	337	8	-	-	SYM
cblr-2960	337	9	91	91	NUM
cblr-2960	337	10	;	;	PUNCT
cblr-2960	337	11	see	see	VERB
cblr-2960	337	12	also	also	ADV
cblr-2960	337	13	i.r.c	i.r.c	NOUN
cblr-2960	337	14	.	.	PUNCT
cblr-2960	338	1	§	§	PROPN
cblr-2960	338	2	§	§	PROPN
cblr-2960	338	3	61	61	NUM
cblr-2960	338	4	,	,	PUNCT
cblr-2960	338	5	7702(g	7702(g	NUM
cblr-2960	338	6	)	)	PUNCT
cblr-2960	338	7	.	.	PUNCT
cblr-2960	339	1	l	l	NOUN
cblr-2960	339	2	see	see	VERB
cblr-2960	339	3	supra	supra	PROPN
cblr-2960	339	4	part	part	PROPN
cblr-2960	339	5	iii.b.1	iii.b.1	PUNCT
cblr-2960	339	6	.	.	PUNCT
cblr-2960	340	1	[	[	X
cblr-2960	340	2	vol	vol	NOUN
cblr-2960	340	3	.	.	NOUN
cblr-2960	340	4	2008	2008	NUM
cblr-2960	340	5	job	job	NOUN
cblr-2960	340	6	well	well	ADV
cblr-2960	340	7	done	do	VERB
cblr-2960	340	8	them	they	PRON
cblr-2960	340	9	to	to	ADP
cblr-2960	340	10	market	market	NOUN
cblr-2960	340	11	compliant	compliant	ADJ
cblr-2960	340	12	products	product	NOUN
cblr-2960	340	13	.	.	PUNCT
cblr-2960	341	1	110	110	NUM
cblr-2960	341	2	for	for	ADP
cblr-2960	341	3	example	example	NOUN
cblr-2960	341	4	,	,	PUNCT
cblr-2960	341	5	insurance	insurance	NOUN
cblr-2960	341	6	companies	company	NOUN
cblr-2960	341	7	may	may	AUX
cblr-2960	341	8	be	be	AUX
cblr-2960	341	9	unwilling	unwilling	ADJ
cblr-2960	341	10	to	to	PART
cblr-2960	341	11	create	create	VERB
cblr-2960	341	12	their	their	PRON
cblr-2960	341	13	own	own	ADJ
cblr-2960	341	14	hedge	hedge	NOUN
cblr-2960	341	15	fund	fund	NOUN
cblr-2960	341	16	for	for	ADP
cblr-2960	341	17	investment	investment	NOUN
cblr-2960	341	18	or	or	CCONJ
cblr-2960	341	19	to	to	PART
cblr-2960	341	20	clone	clone	VERB
cblr-2960	341	21	someone	someone	PRON
cblr-2960	341	22	else	else	ADV
cblr-2960	341	23	's	's	PART
cblr-2960	341	24	hedge	hedge	NOUN
cblr-2960	341	25	fund	fund	NOUN
cblr-2960	341	26	.	.	PUNCT
cblr-2960	342	1	"	"	PUNCT
cblr-2960	342	2	'	'	PUNCT
cblr-2960	342	3	insurance	insurance	NOUN
cblr-2960	342	4	companies	company	NOUN
cblr-2960	342	5	may	may	AUX
cblr-2960	342	6	also	also	ADV
cblr-2960	342	7	be	be	AUX
cblr-2960	342	8	unwilling	unwilling	ADJ
cblr-2960	342	9	to	to	PART
cblr-2960	342	10	persuade	persuade	VERB
cblr-2960	342	11	hedge	hedge	NOUN
cblr-2960	342	12	fund	fund	NOUN
cblr-2960	342	13	managers	manager	NOUN
cblr-2960	342	14	to	to	PART
cblr-2960	342	15	set	set	VERB
cblr-2960	342	16	up	up	ADP
cblr-2960	342	17	special	special	ADJ
cblr-2960	342	18	funds	fund	NOUN
cblr-2960	342	19	specifically	specifically	ADV
cblr-2960	342	20	for	for	ADP
cblr-2960	342	21	insurance	insurance	NOUN
cblr-2960	342	22	contracts.12	contracts.12	NOUN
cblr-2960	342	23	in	in	ADP
cblr-2960	342	24	addition	addition	NOUN
cblr-2960	342	25	,	,	PUNCT
cblr-2960	342	26	life	life	NOUN
cblr-2960	342	27	insurance	insurance	NOUN
cblr-2960	342	28	companies	company	NOUN
cblr-2960	342	29	want	want	VERB
cblr-2960	342	30	to	to	PART
cblr-2960	342	31	be	be	AUX
cblr-2960	342	32	able	able	ADJ
cblr-2960	342	33	to	to	PART
cblr-2960	342	34	put	put	VERB
cblr-2960	342	35	their	their	PRON
cblr-2960	342	36	customers	customer	NOUN
cblr-2960	342	37	in	in	ADP
cblr-2960	342	38	hedge	hedge	NOUN
cblr-2960	342	39	funds	fund	NOUN
cblr-2960	342	40	that	that	PRON
cblr-2960	342	41	are	be	AUX
cblr-2960	342	42	offered	offer	VERB
cblr-2960	342	43	to	to	ADP
cblr-2960	342	44	other	other	ADJ
cblr-2960	342	45	investors	investor	NOUN
cblr-2960	342	46	,	,	PUNCT
cblr-2960	342	47	not	not	PART
cblr-2960	342	48	just	just	ADV
cblr-2960	342	49	hedge	hedge	NOUN
cblr-2960	342	50	funds	fund	NOUN
cblr-2960	342	51	that	that	PRON
cblr-2960	342	52	are	be	AUX
cblr-2960	342	53	offered	offer	VERB
cblr-2960	342	54	to	to	PART
cblr-2960	342	55	separate	separate	VERB
cblr-2960	342	56	accounts	account	NOUN
cblr-2960	342	57	for	for	ADP
cblr-2960	342	58	insurers	insurer	NOUN
cblr-2960	342	59	.	.	PUNCT
cblr-2960	343	1	"	"	PUNCT
cblr-2960	343	2	'	'	PUNCT
cblr-2960	343	3	hedge	hedge	NOUN
cblr-2960	343	4	fund	fund	NOUN
cblr-2960	343	5	alternatives	alternative	NOUN
cblr-2960	343	6	like	like	ADP
cblr-2960	343	7	clones	clone	NOUN
cblr-2960	343	8	of	of	ADP
cblr-2960	343	9	funds	fund	NOUN
cblr-2960	343	10	are	be	AUX
cblr-2960	343	11	often	often	ADV
cblr-2960	343	12	inferior	inferior	ADJ
cblr-2960	343	13	to	to	ADP
cblr-2960	343	14	generally	generally	ADV
cblr-2960	343	15	available	available	ADJ
cblr-2960	343	16	hedge	hedge	NOUN
cblr-2960	343	17	funds	fund	NOUN
cblr-2960	343	18	.	.	PUNCT
cblr-2960	344	1	"	"	PUNCT
cblr-2960	344	2	'	'	PUNCT
cblr-2960	344	3	hedge	hedge	NOUN
cblr-2960	344	4	funds	fund	NOUN
cblr-2960	344	5	are	be	AUX
cblr-2960	344	6	also	also	ADV
cblr-2960	344	7	reluctant	reluctant	ADJ
cblr-2960	344	8	to	to	PART
cblr-2960	344	9	engage	engage	VERB
cblr-2960	344	10	in	in	ADP
cblr-2960	344	11	private	private	ADJ
cblr-2960	344	12	placement	placement	NOUN
cblr-2960	344	13	products	product	NOUN
cblr-2960	344	14	due	due	ADP
cblr-2960	344	15	to	to	ADP
cblr-2960	344	16	the	the	DET
cblr-2960	344	17	recent	recent	ADJ
cblr-2960	344	18	reforms	reform	NOUN
cblr-2960	344	19	.	.	PUNCT
cblr-2960	345	1	hedge	hedge	NOUN
cblr-2960	345	2	funds	fund	NOUN
cblr-2960	345	3	may	may	AUX
cblr-2960	345	4	be	be	AUX
cblr-2960	345	5	unwilling	unwilling	ADJ
cblr-2960	345	6	to	to	PART
cblr-2960	345	7	set	set	VERB
cblr-2960	345	8	up	up	ADP
cblr-2960	345	9	insurance	insurance	NOUN
cblr-2960	345	10	-	-	PUNCT
cblr-2960	345	11	dedicated	dedicate	VERB
cblr-2960	345	12	funds	fund	NOUN
cblr-2960	345	13	specifically	specifically	ADV
cblr-2960	345	14	for	for	ADP
cblr-2960	345	15	insurance	insurance	NOUN
cblr-2960	345	16	companies	company	NOUN
cblr-2960	345	17	.	.	PUNCT
cblr-2960	345	18	"	"	PUNCT
cblr-2960	346	1	5	5	NUM
cblr-2960	346	2	furthermore	furthermore	ADV
cblr-2960	346	3	,	,	PUNCT
cblr-2960	346	4	even	even	ADV
cblr-2960	346	5	if	if	SCONJ
cblr-2960	346	6	funds	fund	NOUN
cblr-2960	346	7	are	be	AUX
cblr-2960	346	8	willing	willing	ADJ
cblr-2960	346	9	to	to	PART
cblr-2960	346	10	set	set	VERB
cblr-2960	346	11	up	up	ADP
cblr-2960	346	12	special	special	ADJ
cblr-2960	346	13	funds	fund	NOUN
cblr-2960	346	14	,	,	PUNCT
cblr-2960	346	15	they	they	PRON
cblr-2960	346	16	may	may	AUX
cblr-2960	346	17	fail	fail	VERB
cblr-2960	346	18	to	to	PART
cblr-2960	346	19	gather	gather	VERB
cblr-2960	346	20	a	a	DET
cblr-2960	346	21	sufficient	sufficient	ADJ
cblr-2960	346	22	number	number	NOUN
cblr-2960	346	23	of	of	ADP
cblr-2960	346	24	insurance	insurance	NOUN
cblr-2960	346	25	-	-	PUNCT
cblr-2960	346	26	dedicated	dedicate	VERB
cblr-2960	346	27	hedge	hedge	NOUN
cblr-2960	346	28	funds	fund	NOUN
cblr-2960	346	29	to	to	PART
cblr-2960	346	30	become	become	VERB
cblr-2960	346	31	or	or	CCONJ
cblr-2960	346	32	remain	remain	VERB
cblr-2960	346	33	viable	viable	ADJ
cblr-2960	346	34	.	.	PUNCT
cblr-2960	347	1	hedge	hedge	NOUN
cblr-2960	347	2	funds	fund	NOUN
cblr-2960	347	3	may	may	AUX
cblr-2960	347	4	also	also	ADV
cblr-2960	347	5	be	be	AUX
cblr-2960	347	6	deterred	deter	VERB
cblr-2960	347	7	from	from	ADP
cblr-2960	347	8	entering	enter	VERB
cblr-2960	347	9	the	the	DET
cblr-2960	347	10	market	market	NOUN
cblr-2960	347	11	after	after	ADP
cblr-2960	347	12	witnessing	witness	VERB
cblr-2960	347	13	the	the	DET
cblr-2960	347	14	failure	failure	NOUN
cblr-2960	347	15	of	of	ADP
cblr-2960	347	16	other	other	ADJ
cblr-2960	347	17	funds	fund	NOUN
cblr-2960	347	18	to	to	PART
cblr-2960	347	19	comply	comply	VERB
cblr-2960	347	20	with	with	ADP
cblr-2960	347	21	the	the	DET
cblr-2960	347	22	relevant	relevant	ADJ
cblr-2960	347	23	tax	tax	NOUN
cblr-2960	347	24	rules	rule	NOUN
cblr-2960	347	25	.	.	PUNCT
cblr-2960	348	1	lastly	lastly	ADV
cblr-2960	348	2	,	,	PUNCT
cblr-2960	348	3	the	the	DET
cblr-2960	348	4	diversification	diversification	NOUN
cblr-2960	348	5	requirements	requirement	NOUN
cblr-2960	348	6	require	require	VERB
cblr-2960	348	7	disclosure	disclosure	NOUN
cblr-2960	348	8	of	of	ADP
cblr-2960	348	9	110	110	NUM
cblr-2960	348	10	see	see	NOUN
cblr-2960	348	11	luke	luke	PROPN
cblr-2960	348	12	,	,	PUNCT
cblr-2960	348	13	supra	supra	PROPN
cblr-2960	348	14	note	note	NOUN
cblr-2960	348	15	3	3	NUM
cblr-2960	348	16	,	,	PUNCT
cblr-2960	348	17	at	at	ADP
cblr-2960	348	18	185	185	NUM
cblr-2960	348	19	(	(	PUNCT
cblr-2960	348	20	explaining	explain	VERB
cblr-2960	348	21	that	that	SCONJ
cblr-2960	348	22	the	the	DET
cblr-2960	348	23	tax	tax	NOUN
cblr-2960	348	24	agencies	agency	NOUN
cblr-2960	348	25	have	have	AUX
cblr-2960	348	26	asserted	assert	VERB
cblr-2960	348	27	that	that	SCONJ
cblr-2960	348	28	the	the	DET
cblr-2960	348	29	investor	investor	NOUN
cblr-2960	348	30	control	control	NOUN
cblr-2960	348	31	doctrine	doctrine	NOUN
cblr-2960	348	32	and	and	CCONJ
cblr-2960	348	33	diversification	diversification	NOUN
cblr-2960	348	34	requirement	requirement	NOUN
cblr-2960	348	35	are	be	AUX
cblr-2960	348	36	"	"	PUNCT
cblr-2960	348	37	strong	strong	ADJ
cblr-2960	348	38	weapons	weapon	NOUN
cblr-2960	348	39	in	in	ADP
cblr-2960	348	40	their	their	PRON
cblr-2960	348	41	war	war	NOUN
cblr-2960	348	42	on	on	ADP
cblr-2960	348	43	tax	tax	NOUN
cblr-2960	348	44	shelters	shelter	NOUN
cblr-2960	348	45	"	"	PUNCT
cblr-2960	348	46	)	)	PUNCT
cblr-2960	348	47	.	.	PUNCT
cblr-2960	349	1	"	"	PUNCT
cblr-2960	349	2	1	1	NUM
cblr-2960	349	3	see	see	VERB
cblr-2960	349	4	sheppard	sheppard	NOUN
cblr-2960	349	5	,	,	PUNCT
cblr-2960	349	6	supra	supra	PROPN
cblr-2960	349	7	note	note	NOUN
cblr-2960	349	8	67	67	NUM
cblr-2960	349	9	.	.	PUNCT
cblr-2960	350	1	see	see	VERB
cblr-2960	350	2	i	i	PRON
cblr-2960	350	3	d.	d.	PROPN
cblr-2960	350	4	(	(	PUNCT
cblr-2960	350	5	arguing	argue	VERB
cblr-2960	350	6	that	that	SCONJ
cblr-2960	350	7	the	the	DET
cblr-2960	350	8	investor	investor	NOUN
cblr-2960	350	9	control	control	NOUN
cblr-2960	350	10	doctrine	doctrine	NOUN
cblr-2960	350	11	requires	require	VERB
cblr-2960	350	12	hedge	hedge	NOUN
cblr-2960	350	13	fund	fund	NOUN
cblr-2960	350	14	managers	manager	NOUN
cblr-2960	350	15	to	to	PART
cblr-2960	350	16	form	form	VERB
cblr-2960	350	17	funds	fund	NOUN
cblr-2960	350	18	that	that	PRON
cblr-2960	350	19	limit	limit	VERB
cblr-2960	350	20	access	access	NOUN
cblr-2960	350	21	to	to	ADP
cblr-2960	350	22	annuity	annuity	NOUN
cblr-2960	350	23	or	or	CCONJ
cblr-2960	350	24	life	life	NOUN
cblr-2960	350	25	insurance	insurance	NOUN
cblr-2960	350	26	contracts	contract	NOUN
cblr-2960	350	27	)	)	PUNCT
cblr-2960	350	28	.	.	PUNCT
cblr-2960	350	29	.	.	PUNCT
cblr-2960	351	1	see	see	VERB
cblr-2960	351	2	i	i	PRON
cblr-2960	351	3	d.	d.	PROPN
cblr-2960	351	4	(	(	PUNCT
cblr-2960	351	5	stating	state	VERB
cblr-2960	351	6	that	that	SCONJ
cblr-2960	351	7	life	life	NOUN
cblr-2960	351	8	insurance	insurance	NOUN
cblr-2960	351	9	companies	company	NOUN
cblr-2960	351	10	want	want	VERB
cblr-2960	351	11	to	to	PART
cblr-2960	351	12	place	place	VERB
cblr-2960	351	13	policyholders	policyholder	NOUN
cblr-2960	351	14	in	in	ADP
cblr-2960	351	15	funds	fund	NOUN
cblr-2960	351	16	that	that	PRON
cblr-2960	351	17	are	be	AUX
cblr-2960	351	18	open	open	ADJ
cblr-2960	351	19	to	to	ADP
cblr-2960	351	20	investors	investor	NOUN
cblr-2960	351	21	of	of	ADP
cblr-2960	351	22	the	the	DET
cblr-2960	351	23	general	general	ADJ
cblr-2960	351	24	public	public	NOUN
cblr-2960	351	25	)	)	PUNCT
cblr-2960	351	26	.	.	PUNCT
cblr-2960	352	1	114	114	NUM
cblr-2960	352	2	see	see	VERB
cblr-2960	352	3	houman	houman	PROPN
cblr-2960	352	4	b.	b.	PROPN
cblr-2960	352	5	shadab	shadab	PROPN
cblr-2960	352	6	,	,	PUNCT
cblr-2960	352	7	the	the	DET
cblr-2960	352	8	definition	definition	NOUN
cblr-2960	352	9	of	of	ADP
cblr-2960	352	10	accredited	accredit	VERB
cblr-2960	352	11	investors	investor	NOUN
cblr-2960	352	12	in	in	ADP
cblr-2960	352	13	certain	certain	ADJ
cblr-2960	352	14	private	private	ADJ
cblr-2960	352	15	investment	investment	NOUN
cblr-2960	352	16	vehicles	vehicle	NOUN
cblr-2960	352	17	19	19	NUM
cblr-2960	352	18	(	(	PUNCT
cblr-2960	352	19	working	working	NOUN
cblr-2960	352	20	paper	paper	NOUN
cblr-2960	352	21	,	,	PUNCT
cblr-2960	352	22	2007	2007	NUM
cblr-2960	352	23	)	)	PUNCT
cblr-2960	352	24	,	,	PUNCT
cblr-2960	352	25	available	available	ADJ
cblr-2960	352	26	at	at	ADP
cblr-2960	352	27	http://ssrn.com/abstract=980751	http://ssrn.com/abstract=980751	PROPN
cblr-2960	352	28	(	(	PUNCT
cblr-2960	352	29	explaining	explain	VERB
cblr-2960	352	30	that	that	DET
cblr-2960	352	31	hedge	hedge	NOUN
cblr-2960	352	32	fund	fund	NOUN
cblr-2960	352	33	alternatives	alternative	NOUN
cblr-2960	352	34	have	have	AUX
cblr-2960	352	35	not	not	PART
cblr-2960	352	36	matched	match	VERB
cblr-2960	352	37	the	the	DET
cblr-2960	352	38	performance	performance	NOUN
cblr-2960	352	39	of	of	ADP
cblr-2960	352	40	the	the	DET
cblr-2960	352	41	best	good	ADJ
cblr-2960	352	42	hedge	hedge	NOUN
cblr-2960	352	43	funds	fund	NOUN
cblr-2960	352	44	which	which	PRON
cblr-2960	352	45	rely	rely	VERB
cblr-2960	352	46	more	more	ADV
cblr-2960	352	47	directly	directly	ADV
cblr-2960	352	48	on	on	ADP
cblr-2960	352	49	human	human	ADJ
cblr-2960	352	50	skill	skill	NOUN
cblr-2960	352	51	)	)	PUNCT
cblr-2960	352	52	.	.	PUNCT
cblr-2960	353	1	115	115	NUM
cblr-2960	353	2	see	see	VERB
cblr-2960	353	3	sheppard	sheppard	NOUN
cblr-2960	353	4	,	,	PUNCT
cblr-2960	353	5	supra	supra	PROPN
cblr-2960	353	6	note	note	NOUN
cblr-2960	353	7	67	67	NUM
cblr-2960	353	8	(	(	PUNCT
cblr-2960	353	9	commenting	comment	VERB
cblr-2960	353	10	that	that	SCONJ
cblr-2960	353	11	hedge	hedge	NOUN
cblr-2960	353	12	funds	fund	NOUN
cblr-2960	353	13	may	may	AUX
cblr-2960	353	14	be	be	AUX
cblr-2960	353	15	unwilling	unwilling	ADJ
cblr-2960	353	16	to	to	PART
cblr-2960	353	17	set	set	VERB
cblr-2960	353	18	up	up	ADP
cblr-2960	353	19	special	special	ADJ
cblr-2960	353	20	funds	fund	NOUN
cblr-2960	353	21	specifically	specifically	ADV
cblr-2960	353	22	for	for	ADP
cblr-2960	353	23	insurers	insurer	NOUN
cblr-2960	353	24	)	)	PUNCT
cblr-2960	353	25	.	.	PUNCT
cblr-2960	354	1	no	no	INTJ
cblr-2960	354	2	.	.	PUNCT
cblr-2960	355	1	2:694	2:694	NUM
cblr-2960	355	2	]	]	X
cblr-2960	355	3	each	each	DET
cblr-2960	355	4	fund	fund	NOUN
cblr-2960	355	5	's	's	PART
cblr-2960	355	6	major	major	ADJ
cblr-2960	355	7	positions	position	NOUN
cblr-2960	355	8	,	,	PUNCT
cblr-2960	355	9	if	if	SCONJ
cblr-2960	355	10	not	not	PART
cblr-2960	355	11	all	all	DET
cblr-2960	355	12	positions	position	NOUN
cblr-2960	355	13	,	,	PUNCT
cblr-2960	355	14	and	and	CCONJ
cblr-2960	355	15	this	this	PRON
cblr-2960	355	16	is	be	AUX
cblr-2960	355	17	something	something	PRON
cblr-2960	355	18	fund	fund	NOUN
cblr-2960	355	19	managers	manager	NOUN
cblr-2960	355	20	are	be	AUX
cblr-2960	355	21	reluctant	reluctant	ADJ
cblr-2960	355	22	to	to	PART
cblr-2960	355	23	do	do	VERB
cblr-2960	355	24	.	.	PUNCT
cblr-2960	355	25	"	"	PUNCT
cblr-2960	356	1	6	6	NUM
cblr-2960	356	2	the	the	DET
cblr-2960	356	3	tax	tax	NOUN
cblr-2960	356	4	reforms	reform	NOUN
cblr-2960	356	5	therefore	therefore	ADV
cblr-2960	356	6	create	create	VERB
cblr-2960	356	7	effective	effective	ADJ
cblr-2960	356	8	frictions	friction	NOUN
cblr-2960	356	9	that	that	PRON
cblr-2960	356	10	discourage	discourage	VERB
cblr-2960	356	11	tax	tax	NOUN
cblr-2960	356	12	accommodation	accommodation	NOUN
cblr-2960	356	13	parties	party	NOUN
cblr-2960	356	14	from	from	ADP
cblr-2960	356	15	providing	provide	VERB
cblr-2960	356	16	tax	tax	NOUN
cblr-2960	356	17	planning	planning	NOUN
cblr-2960	356	18	assistance	assistance	NOUN
cblr-2960	356	19	to	to	ADP
cblr-2960	356	20	the	the	DET
cblr-2960	356	21	taxpayer	taxpayer	NOUN
cblr-2960	356	22	.	.	PUNCT
cblr-2960	357	1	the	the	DET
cblr-2960	357	2	reforms	reform	NOUN
cblr-2960	357	3	have	have	AUX
cblr-2960	357	4	made	make	VERB
cblr-2960	357	5	it	it	PRON
cblr-2960	357	6	more	more	ADV
cblr-2960	357	7	difficult	difficult	ADJ
cblr-2960	357	8	for	for	SCONJ
cblr-2960	357	9	insurance	insurance	NOUN
cblr-2960	357	10	companies	company	NOUN
cblr-2960	357	11	and	and	CCONJ
cblr-2960	357	12	hedge	hedge	NOUN
cblr-2960	357	13	funds	fund	NOUN
cblr-2960	357	14	to	to	PART
cblr-2960	357	15	provide	provide	VERB
cblr-2960	357	16	compliant	compliant	ADJ
cblr-2960	357	17	private	private	ADJ
cblr-2960	357	18	placement	placement	NOUN
cblr-2960	357	19	life	life	NOUN
cblr-2960	357	20	insurance	insurance	NOUN
cblr-2960	357	21	policies	policy	NOUN
cblr-2960	357	22	as	as	ADP
cblr-2960	357	23	a	a	DET
cblr-2960	357	24	tax	tax	NOUN
cblr-2960	357	25	planning	planning	NOUN
cblr-2960	357	26	device	device	NOUN
cblr-2960	357	27	.	.	PUNCT
cblr-2960	358	1	insurance	insurance	NOUN
cblr-2960	358	2	companies	company	NOUN
cblr-2960	358	3	still	still	ADV
cblr-2960	358	4	offer	offer	VERB
cblr-2960	358	5	a	a	DET
cblr-2960	358	6	menu	menu	NOUN
cblr-2960	358	7	of	of	ADP
cblr-2960	358	8	investment	investment	NOUN
cblr-2960	358	9	options	option	NOUN
cblr-2960	358	10	to	to	ADP
cblr-2960	358	11	policyholders	policyholder	NOUN
cblr-2960	358	12	,	,	PUNCT
cblr-2960	358	13	but	but	CCONJ
cblr-2960	358	14	the	the	DET
cblr-2960	358	15	number	number	NOUN
cblr-2960	358	16	of	of	ADP
cblr-2960	358	17	available	available	ADJ
cblr-2960	358	18	options	option	NOUN
cblr-2960	358	19	is	be	AUX
cblr-2960	358	20	significantly	significantly	ADV
cblr-2960	358	21	reduced	reduce	VERB
cblr-2960	358	22	because	because	SCONJ
cblr-2960	358	23	of	of	ADP
cblr-2960	358	24	the	the	DET
cblr-2960	358	25	need	need	NOUN
cblr-2960	358	26	to	to	PART
cblr-2960	358	27	find	find	VERB
cblr-2960	358	28	insurance	insurance	NOUN
cblr-2960	358	29	-	-	PUNCT
cblr-2960	358	30	dedicated	dedicate	VERB
cblr-2960	358	31	hedge	hedge	NOUN
cblr-2960	358	32	funds	fund	NOUN
cblr-2960	358	33	.	.	PUNCT
cblr-2960	358	34	"	"	PUNCT
cblr-2960	359	1	7	7	NUM
cblr-2960	359	2	thus	thus	ADV
cblr-2960	359	3	,	,	PUNCT
cblr-2960	359	4	requiring	require	VERB
cblr-2960	359	5	investors	investor	NOUN
cblr-2960	359	6	to	to	PART
cblr-2960	359	7	persuade	persuade	VERB
cblr-2960	359	8	hedge	hedge	NOUN
cblr-2960	359	9	fund	fund	NOUN
cblr-2960	359	10	managers	manager	NOUN
cblr-2960	359	11	to	to	PART
cblr-2960	359	12	set	set	VERB
cblr-2960	359	13	up	up	ADP
cblr-2960	359	14	special	special	ADJ
cblr-2960	359	15	funds	fund	NOUN
cblr-2960	359	16	for	for	ADP
cblr-2960	359	17	them	they	PRON
cblr-2960	359	18	is	be	AUX
cblr-2960	359	19	precisely	precisely	ADV
cblr-2960	359	20	the	the	DET
cblr-2960	359	21	type	type	NOUN
cblr-2960	359	22	of	of	ADP
cblr-2960	359	23	annoyance	annoyance	NOUN
cblr-2960	359	24	intended	intend	VERB
cblr-2960	359	25	by	by	ADP
cblr-2960	359	26	the	the	DET
cblr-2960	359	27	tax	tax	NOUN
cblr-2960	359	28	agencies	agency	NOUN
cblr-2960	359	29	.	.	PUNCT
cblr-2960	360	1	"	"	PUNCT
cblr-2960	360	2	'	'	PUNCT
cblr-2960	360	3	3	3	X
cblr-2960	360	4	.	.	PUNCT
cblr-2960	360	5	costs	cost	NOUN
cblr-2960	360	6	of	of	ADP
cblr-2960	360	7	compliance	compliance	NOUN
cblr-2960	360	8	the	the	DET
cblr-2960	360	9	costs	cost	NOUN
cblr-2960	360	10	of	of	ADP
cblr-2960	360	11	having	have	VERB
cblr-2960	360	12	to	to	PART
cblr-2960	360	13	comply	comply	VERB
cblr-2960	360	14	with	with	ADP
cblr-2960	360	15	the	the	DET
cblr-2960	360	16	tax	tax	NOUN
cblr-2960	360	17	rules	rule	NOUN
cblr-2960	360	18	increase	increase	VERB
cblr-2960	360	19	deterrent	deterrent	NOUN
cblr-2960	360	20	frictions	friction	NOUN
cblr-2960	360	21	,	,	PUNCT
cblr-2960	360	22	reduce	reduce	VERB
cblr-2960	360	23	the	the	DET
cblr-2960	360	24	taxpayer	taxpayer	NOUN
cblr-2960	360	25	's	's	PART
cblr-2960	360	26	elasticity	elasticity	NOUN
cblr-2960	360	27	of	of	ADP
cblr-2960	360	28	taxable	taxable	ADJ
cblr-2960	360	29	income	income	NOUN
cblr-2960	360	30	,	,	PUNCT
cblr-2960	360	31	and	and	CCONJ
cblr-2960	360	32	minimize	minimize	VERB
cblr-2960	360	33	the	the	DET
cblr-2960	360	34	distortionary	distortionary	ADJ
cblr-2960	360	35	effect	effect	NOUN
cblr-2960	360	36	.	.	PUNCT
cblr-2960	361	1	while	while	SCONJ
cblr-2960	361	2	the	the	DET
cblr-2960	361	3	diversification	diversification	NOUN
cblr-2960	361	4	rule	rule	NOUN
cblr-2960	361	5	does	do	AUX
cblr-2960	361	6	not	not	PART
cblr-2960	361	7	directly	directly	ADV
cblr-2960	361	8	affect	affect	VERB
cblr-2960	361	9	the	the	DET
cblr-2960	361	10	ability	ability	NOUN
cblr-2960	361	11	to	to	PART
cblr-2960	361	12	use	use	VERB
cblr-2960	361	13	hedge	hedge	NOUN
cblr-2960	361	14	fund	fund	NOUN
cblr-2960	361	15	wrappers	wrapper	NOUN
cblr-2960	361	16	,	,	PUNCT
cblr-2960	361	17	it	it	PRON
cblr-2960	361	18	does	do	AUX
cblr-2960	361	19	raise	raise	VERB
cblr-2960	361	20	the	the	DET
cblr-2960	361	21	costs	cost	NOUN
cblr-2960	361	22	of	of	ADP
cblr-2960	361	23	all	all	DET
cblr-2960	361	24	variable	variable	ADJ
cblr-2960	361	25	contracts	contract	NOUN
cblr-2960	361	26	because	because	SCONJ
cblr-2960	361	27	insurance	insurance	NOUN
cblr-2960	361	28	companies	company	NOUN
cblr-2960	361	29	must	must	AUX
cblr-2960	361	30	monitor	monitor	VERB
cblr-2960	361	31	compliance	compliance	NOUN
cblr-2960	361	32	.	.	PUNCT
cblr-2960	361	33	"	"	PUNCT
cblr-2960	362	1	9	9	NUM
cblr-2960	362	2	in	in	ADP
cblr-2960	362	3	order	order	NOUN
cblr-2960	362	4	to	to	PART
cblr-2960	362	5	adhere	adhere	VERB
cblr-2960	362	6	to	to	ADP
cblr-2960	362	7	the	the	DET
cblr-2960	362	8	tax	tax	NOUN
cblr-2960	362	9	rules	rule	NOUN
cblr-2960	362	10	,	,	PUNCT
cblr-2960	362	11	insurance	insurance	NOUN
cblr-2960	362	12	companies	company	NOUN
cblr-2960	362	13	must	must	AUX
cblr-2960	362	14	perform	perform	VERB
cblr-2960	362	15	expensive	expensive	ADJ
cblr-2960	362	16	and	and	CCONJ
cblr-2960	362	17	complicated	complicated	ADJ
cblr-2960	362	18	compliance	compliance	NOUN
cblr-2960	362	19	testing.20	testing.20	NOUN
cblr-2960	362	20	for	for	ADP
cblr-2960	362	21	example	example	NOUN
cblr-2960	362	22	,	,	PUNCT
cblr-2960	362	23	although	although	SCONJ
cblr-2960	362	24	insurance	insurance	NOUN
cblr-2960	362	25	companies	company	NOUN
cblr-2960	362	26	may	may	AUX
cblr-2960	362	27	offer	offer	VERB
cblr-2960	362	28	hedge	hedge	NOUN
cblr-2960	362	29	funds	fund	NOUN
cblr-2960	362	30	that	that	PRON
cblr-2960	362	31	are	be	AUX
cblr-2960	362	32	clones	clone	NOUN
cblr-2960	362	33	of	of	ADP
cblr-2960	362	34	publicly	publicly	ADV
cblr-2960	362	35	available	available	ADJ
cblr-2960	362	36	hedge	hedge	NOUN
cblr-2960	362	37	funds	fund	NOUN
cblr-2960	362	38	,	,	PUNCT
cblr-2960	362	39	these	these	DET
cblr-2960	362	40	funds	fund	NOUN
cblr-2960	362	41	come	come	VERB
cblr-2960	362	42	at	at	ADP
cblr-2960	362	43	an	an	DET
cblr-2960	362	44	increased	increase	VERB
cblr-2960	362	45	cost	cost	NOUN
cblr-2960	362	46	.	.	PUNCT
cblr-2960	363	1	"	"	PUNCT
cblr-2960	363	2	'	'	PUNCT
cblr-2960	363	3	it	it	PRON
cblr-2960	363	4	may	may	AUX
cblr-2960	363	5	cost	cost	VERB
cblr-2960	363	6	from	from	ADP
cblr-2960	363	7	$	$	SYM
cblr-2960	363	8	10,000	10,000	NUM
cblr-2960	363	9	to	to	PART
cblr-2960	363	10	$	$	SYM
cblr-2960	363	11	20,000	20,000	NUM
cblr-2960	363	12	in	in	ADP
cblr-2960	363	13	legal	legal	ADJ
cblr-2960	363	14	or	or	CCONJ
cblr-2960	363	15	116	116	NUM
cblr-2960	363	16	see	see	NOUN
cblr-2960	363	17	neufeld	neufeld	PROPN
cblr-2960	363	18	,	,	PUNCT
cblr-2960	363	19	supra	supra	PROPN
cblr-2960	363	20	note	note	PROPN
cblr-2960	363	21	42	42	NUM
cblr-2960	363	22	,	,	PUNCT
cblr-2960	363	23	at	at	ADP
cblr-2960	363	24	1194	1194	NUM
cblr-2960	363	25	(	(	PUNCT
cblr-2960	363	26	arguing	argue	VERB
cblr-2960	363	27	that	that	SCONJ
cblr-2960	363	28	the	the	DET
cblr-2960	363	29	diversification	diversification	NOUN
cblr-2960	363	30	requirement	requirement	NOUN
cblr-2960	363	31	requires	require	VERB
cblr-2960	363	32	each	each	DET
cblr-2960	363	33	fund	fund	NOUN
cblr-2960	363	34	to	to	PART
cblr-2960	363	35	disclose	disclose	VERB
cblr-2960	363	36	positions	position	NOUN
cblr-2960	363	37	,	,	PUNCT
cblr-2960	363	38	thereby	thereby	ADV
cblr-2960	363	39	revealing	reveal	VERB
cblr-2960	363	40	private	private	ADJ
cblr-2960	363	41	investment	investment	NOUN
cblr-2960	363	42	decisions	decision	NOUN
cblr-2960	363	43	and	and	CCONJ
cblr-2960	363	44	strategies	strategy	NOUN
cblr-2960	363	45	)	)	PUNCT
cblr-2960	363	46	.	.	PUNCT
cblr-2960	364	1	117	117	NUM
cblr-2960	364	2	see	see	VERB
cblr-2960	364	3	supra	supra	PROPN
cblr-2960	364	4	part	part	NOUN
cblr-2960	364	5	iii.b	iii.b	PROPN
cblr-2960	364	6	.	.	PUNCT
cblr-2960	365	1	118	118	NUM
cblr-2960	365	2	see	see	VERB
cblr-2960	365	3	neufeld	neufeld	PROPN
cblr-2960	365	4	,	,	PUNCT
cblr-2960	365	5	supra	supra	PROPN
cblr-2960	365	6	note	note	PROPN
cblr-2960	365	7	42	42	NUM
cblr-2960	365	8	,	,	PUNCT
cblr-2960	365	9	at	at	ADP
cblr-2960	365	10	1194	1194	NUM
cblr-2960	365	11	.	.	PUNCT
cblr-2960	366	1	19	19	NUM
cblr-2960	366	2	see	see	VERB
cblr-2960	366	3	luke	luke	PROPN
cblr-2960	366	4	,	,	PUNCT
cblr-2960	366	5	supra	supra	PROPN
cblr-2960	366	6	note	note	NOUN
cblr-2960	366	7	3	3	NUM
cblr-2960	366	8	,	,	PUNCT
cblr-2960	366	9	at	at	ADP
cblr-2960	366	10	187	187	NUM
cblr-2960	366	11	-	-	SYM
cblr-2960	366	12	88	88	NUM
cblr-2960	366	13	.	.	PUNCT
cblr-2960	367	1	120	120	NUM
cblr-2960	367	2	see	see	VERB
cblr-2960	367	3	neufeld	neufeld	PROPN
cblr-2960	367	4	,	,	PUNCT
cblr-2960	367	5	supra	supra	PROPN
cblr-2960	367	6	note	note	PROPN
cblr-2960	367	7	42	42	NUM
cblr-2960	367	8	,	,	PUNCT
cblr-2960	367	9	at	at	ADP
cblr-2960	367	10	1194	1194	NUM
cblr-2960	367	11	(	(	PUNCT
cblr-2960	367	12	explaining	explain	VERB
cblr-2960	367	13	that	that	SCONJ
cblr-2960	367	14	elaborate	elaborate	ADJ
cblr-2960	367	15	diversification	diversification	NOUN
cblr-2960	367	16	testing	testing	NOUN
cblr-2960	367	17	is	be	AUX
cblr-2960	367	18	required	require	VERB
cblr-2960	367	19	of	of	ADP
cblr-2960	367	20	all	all	DET
cblr-2960	367	21	assets	asset	NOUN
cblr-2960	367	22	underlying	underlie	VERB
cblr-2960	367	23	each	each	DET
cblr-2960	367	24	fund	fund	NOUN
cblr-2960	367	25	owned	own	VERB
cblr-2960	367	26	by	by	ADP
cblr-2960	367	27	the	the	DET
cblr-2960	367	28	variable	variable	ADJ
cblr-2960	367	29	contract	contract	NOUN
cblr-2960	367	30	)	)	PUNCT
cblr-2960	367	31	.	.	PUNCT
cblr-2960	368	1	12	12	NUM
cblr-2960	368	2	see	see	VERB
cblr-2960	368	3	luke	luke	PROPN
cblr-2960	368	4	,	,	PUNCT
cblr-2960	368	5	supra	supra	PROPN
cblr-2960	368	6	note	note	NOUN
cblr-2960	368	7	12	12	NUM
cblr-2960	368	8	,	,	PUNCT
cblr-2960	368	9	at	at	ADP
cblr-2960	368	10	282	282	NUM
cblr-2960	368	11	(	(	PUNCT
cblr-2960	368	12	explaining	explain	VERB
cblr-2960	368	13	that	that	SCONJ
cblr-2960	368	14	while	while	SCONJ
cblr-2960	368	15	it	it	PRON
cblr-2960	368	16	is	be	AUX
cblr-2960	368	17	clearly	clearly	ADV
cblr-2960	368	18	impermissible	impermissible	ADJ
cblr-2960	368	19	to	to	PART
cblr-2960	368	20	enclose	enclose	VERB
cblr-2960	368	21	a	a	DET
cblr-2960	368	22	publicly	publicly	ADV
cblr-2960	368	23	available	available	ADJ
cblr-2960	368	24	hedge	hedge	NOUN
cblr-2960	368	25	fund	fund	NOUN
cblr-2960	368	26	interest	interest	NOUN
cblr-2960	368	27	inside	inside	ADP
cblr-2960	368	28	a	a	DET
cblr-2960	368	29	[	[	X
cblr-2960	368	30	vol	vol	NOUN
cblr-2960	368	31	.	.	PUNCT
cblr-2960	369	1	2008columbia	2008columbia	NUM
cblr-2960	369	2	b	b	X
cblr-2960	369	3	usiness	usiness	PROPN
cblr-2960	369	4	la	la	PROPN
cblr-2960	369	5	w	w	PROPN
cblr-2960	369	6	re	re	PROPN
cblr-2960	369	7	vie	vie	PROPN
cblr-2960	369	8	w	w	PROPN
cblr-2960	369	9	job	job	NOUN
cblr-2960	369	10	well	well	ADV
cblr-2960	369	11	done	do	VERB
cblr-2960	369	12	advisory	advisory	ADJ
cblr-2960	369	13	fees	fee	NOUN
cblr-2960	369	14	to	to	PART
cblr-2960	369	15	set	set	VERB
cblr-2960	369	16	up	up	ADP
cblr-2960	369	17	a	a	DET
cblr-2960	369	18	policy.122	policy.122	NOUN
cblr-2960	369	19	consequently	consequently	ADV
cblr-2960	369	20	,	,	PUNCT
cblr-2960	369	21	these	these	DET
cblr-2960	369	22	increased	increase	VERB
cblr-2960	369	23	costs	cost	NOUN
cblr-2960	369	24	are	be	AUX
cblr-2960	369	25	passed	pass	VERB
cblr-2960	369	26	on	on	ADP
cblr-2960	369	27	to	to	ADP
cblr-2960	369	28	the	the	DET
cblr-2960	369	29	taxpayer	taxpayer	NOUN
cblr-2960	369	30	investor	investor	NOUN
cblr-2960	369	31	.	.	PUNCT
cblr-2960	370	1	therefore	therefore	ADV
cblr-2960	370	2	,	,	PUNCT
cblr-2960	370	3	private	private	ADJ
cblr-2960	370	4	placement	placement	NOUN
cblr-2960	370	5	life	life	NOUN
cblr-2960	370	6	insurance	insurance	NOUN
cblr-2960	370	7	policies	policy	NOUN
cblr-2960	370	8	have	have	VERB
cblr-2960	370	9	costs	cost	NOUN
cblr-2960	370	10	that	that	PRON
cblr-2960	370	11	will	will	AUX
cblr-2960	370	12	deter	deter	VERB
cblr-2960	370	13	investors	investor	NOUN
cblr-2960	370	14	from	from	ADP
cblr-2960	370	15	using	use	VERB
cblr-2960	370	16	private	private	ADJ
cblr-2960	370	17	placement	placement	NOUN
cblr-2960	370	18	life	life	NOUN
cblr-2960	370	19	insurance	insurance	NOUN
cblr-2960	370	20	as	as	ADP
cblr-2960	370	21	a	a	DET
cblr-2960	370	22	tax	tax	NOUN
cblr-2960	370	23	planning	planning	NOUN
cblr-2960	370	24	mechanism	mechanism	NOUN
cblr-2960	370	25	.	.	PUNCT
cblr-2960	371	1	the	the	DET
cblr-2960	371	2	increased	increase	VERB
cblr-2960	371	3	costs	cost	NOUN
cblr-2960	371	4	of	of	ADP
cblr-2960	371	5	compliance	compliance	NOUN
cblr-2960	371	6	resulting	result	VERB
cblr-2960	371	7	from	from	ADP
cblr-2960	371	8	the	the	DET
cblr-2960	371	9	tax	tax	NOUN
cblr-2960	371	10	rules	rule	NOUN
cblr-2960	371	11	are	be	AUX
cblr-2960	371	12	effective	effective	ADJ
cblr-2960	371	13	frictions	friction	NOUN
cblr-2960	371	14	against	against	ADP
cblr-2960	371	15	private	private	ADJ
cblr-2960	371	16	placement	placement	NOUN
cblr-2960	371	17	life	life	NOUN
cblr-2960	371	18	insurance	insurance	NOUN
cblr-2960	371	19	wrappers	wrapper	NOUN
cblr-2960	371	20	.	.	PUNCT
cblr-2960	372	1	the	the	DET
cblr-2960	372	2	costs	cost	NOUN
cblr-2960	372	3	of	of	ADP
cblr-2960	372	4	compliance	compliance	NOUN
cblr-2960	372	5	increase	increase	NOUN
cblr-2960	372	6	frictions	friction	NOUN
cblr-2960	372	7	that	that	PRON
cblr-2960	372	8	are	be	AUX
cblr-2960	372	9	both	both	ADV
cblr-2960	372	10	rigid	rigid	ADJ
cblr-2960	372	11	and	and	CCONJ
cblr-2960	372	12	strong	strong	ADJ
cblr-2960	372	13	.	.	PUNCT
cblr-2960	373	1	the	the	DET
cblr-2960	373	2	costs	cost	NOUN
cblr-2960	373	3	of	of	ADP
cblr-2960	373	4	compliance	compliance	NOUN
cblr-2960	373	5	are	be	AUX
cblr-2960	373	6	rigid	rigid	ADJ
cblr-2960	373	7	frictions	friction	NOUN
cblr-2960	373	8	because	because	SCONJ
cblr-2960	373	9	the	the	DET
cblr-2960	373	10	taxpayer	taxpayer	NOUN
cblr-2960	373	11	investor	investor	NOUN
cblr-2960	373	12	can	can	AUX
cblr-2960	373	13	not	not	PART
cblr-2960	373	14	sidestep	sidestep	VERB
cblr-2960	373	15	the	the	DET
cblr-2960	373	16	costs	cost	NOUN
cblr-2960	373	17	without	without	ADP
cblr-2960	373	18	exiting	exit	VERB
cblr-2960	373	19	the	the	DET
cblr-2960	373	20	private	private	ADJ
cblr-2960	373	21	placement	placement	NOUN
cblr-2960	373	22	industry	industry	NOUN
cblr-2960	373	23	.	.	PUNCT
cblr-2960	374	1	increased	increase	VERB
cblr-2960	374	2	costs	cost	NOUN
cblr-2960	374	3	are	be	AUX
cblr-2960	374	4	also	also	ADV
cblr-2960	374	5	strong	strong	ADJ
cblr-2960	374	6	frictions	friction	NOUN
cblr-2960	374	7	,	,	PUNCT
cblr-2960	374	8	causing	cause	VERB
cblr-2960	374	9	the	the	DET
cblr-2960	374	10	taxpayer	taxpayer	NOUN
cblr-2960	374	11	to	to	PART
cblr-2960	374	12	incur	incur	VERB
cblr-2960	374	13	a	a	DET
cblr-2960	374	14	significant	significant	ADJ
cblr-2960	374	15	monetary	monetary	ADJ
cblr-2960	374	16	inconvenience	inconvenience	NOUN
cblr-2960	374	17	.	.	PUNCT
cblr-2960	375	1	the	the	DET
cblr-2960	375	2	increased	increase	VERB
cblr-2960	375	3	cost	cost	NOUN
cblr-2960	375	4	of	of	ADP
cblr-2960	375	5	compliance	compliance	NOUN
cblr-2960	375	6	cuts	cut	NOUN
cblr-2960	375	7	into	into	ADP
cblr-2960	375	8	the	the	DET
cblr-2960	375	9	tax	tax	NOUN
cblr-2960	375	10	benefit	benefit	NOUN
cblr-2960	375	11	,	,	PUNCT
cblr-2960	375	12	lowering	lower	VERB
cblr-2960	375	13	the	the	DET
cblr-2960	375	14	overall	overall	ADJ
cblr-2960	375	15	value	value	NOUN
cblr-2960	375	16	of	of	ADP
cblr-2960	375	17	the	the	DET
cblr-2960	375	18	investment	investment	NOUN
cblr-2960	375	19	vehicle	vehicle	NOUN
cblr-2960	375	20	.	.	PUNCT
cblr-2960	376	1	if	if	SCONJ
cblr-2960	376	2	the	the	DET
cblr-2960	376	3	tax	tax	NOUN
cblr-2960	376	4	benefit	benefit	NOUN
cblr-2960	376	5	is	be	AUX
cblr-2960	376	6	clearly	clearly	ADV
cblr-2960	376	7	greater	great	ADJ
cblr-2960	376	8	than	than	ADP
cblr-2960	376	9	the	the	DET
cblr-2960	376	10	increased	increase	VERB
cblr-2960	376	11	costs	cost	NOUN
cblr-2960	376	12	caused	cause	VERB
cblr-2960	376	13	by	by	ADP
cblr-2960	376	14	the	the	DET
cblr-2960	376	15	tax	tax	NOUN
cblr-2960	376	16	agencies	agency	NOUN
cblr-2960	376	17	'	'	PART
cblr-2960	376	18	reforms	reform	NOUN
cblr-2960	376	19	,	,	PUNCT
cblr-2960	376	20	the	the	DET
cblr-2960	376	21	market	market	NOUN
cblr-2960	376	22	would	would	AUX
cblr-2960	376	23	reflect	reflect	VERB
cblr-2960	376	24	a	a	DET
cblr-2960	376	25	greater	great	ADJ
cblr-2960	376	26	number	number	NOUN
cblr-2960	376	27	of	of	ADP
cblr-2960	376	28	investors	investor	NOUN
cblr-2960	376	29	purchasing	purchase	VERB
cblr-2960	376	30	private	private	ADJ
cblr-2960	376	31	placement	placement	NOUN
cblr-2960	376	32	products	product	NOUN
cblr-2960	376	33	.	.	PUNCT
cblr-2960	377	1	experience	experience	NOUN
cblr-2960	377	2	clearly	clearly	ADV
cblr-2960	377	3	points	point	VERB
cblr-2960	377	4	to	to	ADP
cblr-2960	377	5	the	the	DET
cblr-2960	377	6	contrary	contrary	NOUN
cblr-2960	377	7	.	.	PUNCT
cblr-2960	378	1	23	23	NUM
cblr-2960	379	1	the	the	DET
cblr-2960	379	2	tax	tax	NOUN
cblr-2960	379	3	reforms	reform	NOUN
cblr-2960	379	4	are	be	AUX
cblr-2960	379	5	strong	strong	ADJ
cblr-2960	379	6	anti	anti	ADJ
cblr-2960	379	7	-	-	ADJ
cblr-2960	379	8	avoidance	avoidance	ADJ
cblr-2960	379	9	measures	measure	NOUN
cblr-2960	379	10	that	that	PRON
cblr-2960	379	11	reduce	reduce	VERB
cblr-2960	379	12	the	the	DET
cblr-2960	379	13	taxpayer	taxpayer	NOUN
cblr-2960	379	14	's	's	PART
cblr-2960	379	15	elasticity	elasticity	NOUN
cblr-2960	379	16	of	of	ADP
cblr-2960	379	17	taxable	taxable	ADJ
cblr-2960	379	18	income	income	NOUN
cblr-2960	379	19	by	by	ADP
cblr-2960	379	20	increasing	increase	VERB
cblr-2960	379	21	the	the	DET
cblr-2960	379	22	costs	cost	NOUN
cblr-2960	379	23	of	of	ADP
cblr-2960	379	24	all	all	DET
cblr-2960	379	25	life	life	NOUN
cblr-2960	379	26	insurance	insurance	NOUN
cblr-2960	379	27	contracts	contract	NOUN
cblr-2960	379	28	seeking	seek	VERB
cblr-2960	379	29	to	to	PART
cblr-2960	379	30	wrap	wrap	VERB
cblr-2960	379	31	hedge	hedge	NOUN
cblr-2960	379	32	fund	fund	NOUN
cblr-2960	379	33	investments	investment	NOUN
cblr-2960	379	34	.	.	PUNCT
cblr-2960	380	1	the	the	DET
cblr-2960	380	2	costs	cost	NOUN
cblr-2960	380	3	of	of	ADP
cblr-2960	380	4	compliance	compliance	NOUN
cblr-2960	380	5	affect	affect	VERB
cblr-2960	380	6	all	all	DET
cblr-2960	380	7	insurance	insurance	NOUN
cblr-2960	380	8	wrappers	wrapper	NOUN
cblr-2960	380	9	,	,	PUNCT
cblr-2960	380	10	reducing	reduce	VERB
cblr-2960	380	11	the	the	DET
cblr-2960	380	12	taxpayer	taxpayer	NOUN
cblr-2960	380	13	's	's	PART
cblr-2960	380	14	ability	ability	NOUN
cblr-2960	380	15	to	to	PART
cblr-2960	380	16	avoid	avoid	VERB
cblr-2960	380	17	the	the	DET
cblr-2960	380	18	reforms	reform	NOUN
cblr-2960	380	19	by	by	ADP
cblr-2960	380	20	engaging	engage	VERB
cblr-2960	380	21	in	in	ADP
cblr-2960	380	22	other	other	ADJ
cblr-2960	380	23	life	life	NOUN
cblr-2960	380	24	insurance	insurance	NOUN
cblr-2960	380	25	shelters	shelter	NOUN
cblr-2960	380	26	.	.	PUNCT
cblr-2960	381	1	the	the	DET
cblr-2960	381	2	reforms	reform	NOUN
cblr-2960	381	3	prove	prove	VERB
cblr-2960	381	4	to	to	PART
cblr-2960	381	5	be	be	AUX
cblr-2960	381	6	strong	strong	ADJ
cblr-2960	381	7	anti	anti	ADJ
cblr-2960	381	8	-	-	ADJ
cblr-2960	381	9	avoidance	avoidance	ADJ
cblr-2960	381	10	measures	measure	NOUN
cblr-2960	381	11	because	because	SCONJ
cblr-2960	381	12	the	the	DET
cblr-2960	381	13	increased	increase	VERB
cblr-2960	381	14	costs	cost	NOUN
cblr-2960	381	15	prohibit	prohibit	VERB
cblr-2960	381	16	shifting	shift	VERB
cblr-2960	381	17	into	into	ADP
cblr-2960	381	18	any	any	DET
cblr-2960	381	19	form	form	NOUN
cblr-2960	381	20	of	of	ADP
cblr-2960	381	21	private	private	ADJ
cblr-2960	381	22	placement	placement	NOUN
cblr-2960	381	23	life	life	NOUN
cblr-2960	381	24	insurance	insurance	NOUN
cblr-2960	381	25	as	as	ADP
cblr-2960	381	26	a	a	DET
cblr-2960	381	27	tax	tax	NOUN
cblr-2960	381	28	planning	planning	NOUN
cblr-2960	381	29	scheme	scheme	NOUN
cblr-2960	381	30	.	.	PUNCT
cblr-2960	382	1	unfortunately	unfortunately	ADV
cblr-2960	382	2	,	,	PUNCT
cblr-2960	382	3	there	there	PRON
cblr-2960	382	4	will	will	AUX
cblr-2960	382	5	be	be	AUX
cblr-2960	382	6	a	a	DET
cblr-2960	382	7	number	number	NOUN
cblr-2960	382	8	of	of	ADP
cblr-2960	382	9	private	private	ADJ
cblr-2960	382	10	placement	placement	NOUN
cblr-2960	382	11	life	life	NOUN
cblr-2960	382	12	insurance	insurance	NOUN
cblr-2960	382	13	contract	contract	NOUN
cblr-2960	382	14	under	under	ADP
cblr-2960	382	15	the	the	DET
cblr-2960	382	16	current	current	ADJ
cblr-2960	382	17	regulations	regulation	NOUN
cblr-2960	382	18	,	,	PUNCT
cblr-2960	382	19	the	the	DET
cblr-2960	382	20	tax	tax	NOUN
cblr-2960	382	21	agencies	agency	NOUN
cblr-2960	382	22	have	have	AUX
cblr-2960	382	23	not	not	PART
cblr-2960	382	24	attempted	attempt	VERB
cblr-2960	382	25	to	to	PART
cblr-2960	382	26	use	use	VERB
cblr-2960	382	27	the	the	DET
cblr-2960	382	28	investor	investor	NOUN
cblr-2960	382	29	control	control	NOUN
cblr-2960	382	30	doctrine	doctrine	NOUN
cblr-2960	382	31	to	to	PART
cblr-2960	382	32	go	go	VERB
cblr-2960	382	33	after	after	ADP
cblr-2960	382	34	clones	clone	NOUN
cblr-2960	382	35	of	of	ADP
cblr-2960	382	36	publicly	publicly	ADV
cblr-2960	382	37	available	available	ADJ
cblr-2960	382	38	hedge	hedge	NOUN
cblr-2960	382	39	funds	fund	NOUN
cblr-2960	382	40	)	)	PUNCT
cblr-2960	382	41	;	;	PUNCT
cblr-2960	382	42	see	see	VERB
cblr-2960	382	43	also	also	ADV
cblr-2960	382	44	michael	michael	PROPN
cblr-2960	382	45	a.	a.	PROPN
cblr-2960	382	46	heimos	heimos	PROPN
cblr-2960	382	47	,	,	PUNCT
cblr-2960	382	48	attorney	attorney	NOUN
cblr-2960	382	49	critiques	critique	VERB
cblr-2960	382	50	regs	reg	NOUN
cblr-2960	382	51	targeting	target	VERB
cblr-2960	382	52	use	use	NOUN
cblr-2960	382	53	of	of	ADP
cblr-2960	382	54	annuity	annuity	NOUN
cblr-2960	382	55	contracts	contract	NOUN
cblr-2960	382	56	,	,	PUNCT
cblr-2960	382	57	life	life	NOUN
cblr-2960	382	58	insurance	insurance	NOUN
cblr-2960	382	59	as	as	ADP
cblr-2960	382	60	tax	tax	NOUN
cblr-2960	382	61	avoidance	avoidance	NOUN
cblr-2960	382	62	vehicles	vehicle	NOUN
cblr-2960	382	63	,	,	PUNCT
cblr-2960	382	64	2003	2003	NUM
cblr-2960	382	65	tax	tax	NOUN
cblr-2960	382	66	notes	note	VERB
cblr-2960	382	67	210	210	NUM
cblr-2960	382	68	-	-	SYM
cblr-2960	382	69	51	51	NUM
cblr-2960	382	70	,	,	PUNCT
cblr-2960	382	71	oct	oct	PROPN
cblr-2960	382	72	.	.	PROPN
cblr-2960	382	73	30	30	NUM
cblr-2960	382	74	,	,	PUNCT
cblr-2960	382	75	2003	2003	NUM
cblr-2960	382	76	.	.	PUNCT
cblr-2960	383	1	122	122	NUM
cblr-2960	383	2	i	i	PROPN
cblr-2960	383	3	d.	d.	PROPN
cblr-2960	383	4	;	;	PUNCT
cblr-2960	383	5	see	see	VERB
cblr-2960	383	6	also	also	ADV
cblr-2960	383	7	silverman	silverman	NOUN
cblr-2960	383	8	,	,	PUNCT
cblr-2960	383	9	supra	supra	PROPN
cblr-2960	383	10	note	note	PROPN
cblr-2960	383	11	6	6	NUM
cblr-2960	383	12	(	(	PUNCT
cblr-2960	383	13	commenting	comment	VERB
cblr-2960	383	14	that	that	SCONJ
cblr-2960	383	15	the	the	DET
cblr-2960	383	16	recent	recent	ADJ
cblr-2960	383	17	reforms	reform	NOUN
cblr-2960	383	18	require	require	VERB
cblr-2960	383	19	lawyers	lawyer	NOUN
cblr-2960	383	20	to	to	PART
cblr-2960	383	21	provide	provide	VERB
cblr-2960	383	22	more	more	ADV
cblr-2960	383	23	detailed	detailed	ADJ
cblr-2960	383	24	analyses	analysis	NOUN
cblr-2960	383	25	when	when	SCONJ
cblr-2960	383	26	drafting	draft	VERB
cblr-2960	383	27	a	a	DET
cblr-2960	383	28	formal	formal	ADJ
cblr-2960	383	29	legal	legal	ADJ
cblr-2960	383	30	opinion	opinion	NOUN
cblr-2960	383	31	about	about	ADP
cblr-2960	383	32	certain	certain	ADJ
cblr-2960	383	33	tax	tax	NOUN
cblr-2960	383	34	strategies	strategy	NOUN
cblr-2960	383	35	)	)	PUNCT
cblr-2960	383	36	.	.	PUNCT
cblr-2960	384	1	123	123	NUM
cblr-2960	384	2	see	see	VERB
cblr-2960	384	3	infra	infra	NOUN
cblr-2960	384	4	part	part	NOUN
cblr-2960	384	5	v.b	v.b	PROPN
cblr-2960	384	6	.	.	PROPN
cblr-2960	385	1	no	no	INTJ
cblr-2960	385	2	.	.	PUNCT
cblr-2960	386	1	2:694	2:694	NUM
cblr-2960	386	2	]	]	SYM
cblr-2960	386	3	taxpayers	taxpayer	NOUN
cblr-2960	386	4	whose	whose	DET
cblr-2960	386	5	tax	tax	NOUN
cblr-2960	386	6	benefit	benefit	NOUN
cblr-2960	386	7	continues	continue	VERB
cblr-2960	386	8	to	to	PART
cblr-2960	386	9	outweigh	outweigh	VERB
cblr-2960	386	10	the	the	DET
cblr-2960	386	11	increased	increase	VERB
cblr-2960	386	12	costs	cost	NOUN
cblr-2960	386	13	of	of	ADP
cblr-2960	386	14	the	the	DET
cblr-2960	386	15	reforms	reform	NOUN
cblr-2960	386	16	.	.	PUNCT
cblr-2960	387	1	these	these	DET
cblr-2960	387	2	taxpayers	taxpayer	NOUN
cblr-2960	387	3	that	that	PRON
cblr-2960	387	4	engage	engage	VERB
cblr-2960	387	5	in	in	ADP
cblr-2960	387	6	the	the	DET
cblr-2960	387	7	tax	tax	NOUN
cblr-2960	387	8	planning	planning	NOUN
cblr-2960	387	9	device	device	NOUN
cblr-2960	387	10	notwithstanding	notwithstanding	ADP
cblr-2960	387	11	the	the	DET
cblr-2960	387	12	higher	high	ADJ
cblr-2960	387	13	costs	cost	NOUN
cblr-2960	387	14	of	of	ADP
cblr-2960	387	15	compliance	compliance	NOUN
cblr-2960	387	16	represent	represent	VERB
cblr-2960	387	17	the	the	DET
cblr-2960	387	18	distortionary	distortionary	ADJ
cblr-2960	387	19	effect	effect	NOUN
cblr-2960	387	20	of	of	ADP
cblr-2960	387	21	the	the	DET
cblr-2960	387	22	targeted	target	VERB
cblr-2960	387	23	reforms	reform	NOUN
cblr-2960	387	24	.	.	PUNCT
cblr-2960	388	1	nevertheless	nevertheless	ADV
cblr-2960	388	2	,	,	PUNCT
cblr-2960	388	3	the	the	DET
cblr-2960	388	4	lack	lack	NOUN
cblr-2960	388	5	of	of	ADP
cblr-2960	388	6	market	market	NOUN
cblr-2960	388	7	penetration	penetration	NOUN
cblr-2960	388	8	of	of	ADP
cblr-2960	388	9	private	private	ADJ
cblr-2960	388	10	placement	placement	NOUN
cblr-2960	388	11	products	product	NOUN
cblr-2960	388	12	shows	show	VERB
cblr-2960	388	13	that	that	SCONJ
cblr-2960	388	14	distortionary	distortionary	ADJ
cblr-2960	388	15	activity	activity	NOUN
cblr-2960	388	16	is	be	AUX
cblr-2960	388	17	very	very	ADV
cblr-2960	388	18	low	low	ADJ
cblr-2960	388	19	.	.	PUNCT
cblr-2960	389	1	the	the	DET
cblr-2960	389	2	tax	tax	NOUN
cblr-2960	389	3	reforms	reform	NOUN
cblr-2960	389	4	have	have	AUX
cblr-2960	389	5	thus	thus	ADV
cblr-2960	389	6	been	be	AUX
cblr-2960	389	7	effective	effective	ADJ
cblr-2960	389	8	in	in	ADP
cblr-2960	389	9	minimizing	minimize	VERB
cblr-2960	389	10	the	the	DET
cblr-2960	389	11	waste	waste	NOUN
cblr-2960	389	12	of	of	ADP
cblr-2960	389	13	resources	resource	NOUN
cblr-2960	389	14	caused	cause	VERB
cblr-2960	389	15	by	by	ADP
cblr-2960	389	16	taxpayers	taxpayer	NOUN
cblr-2960	389	17	engaging	engage	VERB
cblr-2960	389	18	in	in	ADP
cblr-2960	389	19	a	a	DET
cblr-2960	389	20	more	more	ADV
cblr-2960	389	21	costly	costly	ADJ
cblr-2960	389	22	tax	tax	NOUN
cblr-2960	389	23	planning	planning	NOUN
cblr-2960	389	24	device	device	NOUN
cblr-2960	389	25	.	.	PUNCT
cblr-2960	390	1	therefore	therefore	ADV
cblr-2960	390	2	,	,	PUNCT
cblr-2960	390	3	the	the	DET
cblr-2960	390	4	costs	cost	NOUN
cblr-2960	390	5	of	of	ADP
cblr-2960	390	6	compliance	compliance	NOUN
cblr-2960	390	7	have	have	AUX
cblr-2960	390	8	effectively	effectively	ADV
cblr-2960	390	9	reduced	reduce	VERB
cblr-2960	390	10	the	the	DET
cblr-2960	390	11	taxpayer	taxpayer	NOUN
cblr-2960	390	12	's	's	PART
cblr-2960	390	13	elasticity	elasticity	NOUN
cblr-2960	390	14	of	of	ADP
cblr-2960	390	15	taxable	taxable	ADJ
cblr-2960	390	16	income	income	NOUN
cblr-2960	390	17	to	to	PART
cblr-2960	390	18	engage	engage	VERB
cblr-2960	390	19	in	in	ADP
cblr-2960	390	20	private	private	ADJ
cblr-2960	390	21	placement	placement	NOUN
cblr-2960	390	22	life	life	NOUN
cblr-2960	390	23	insurance	insurance	NOUN
cblr-2960	390	24	and	and	CCONJ
cblr-2960	390	25	have	have	AUX
cblr-2960	390	26	limited	limit	VERB
cblr-2960	390	27	the	the	DET
cblr-2960	390	28	reforms	reform	NOUN
cblr-2960	390	29	'	'	PART
cblr-2960	390	30	distortionary	distortionary	ADJ
cblr-2960	390	31	effect	effect	NOUN
cblr-2960	390	32	.	.	PUNCT
cblr-2960	391	1	4	4	X
cblr-2960	391	2	.	.	X
cblr-2960	391	3	external	external	ADJ
cblr-2960	391	4	constraints	constraint	NOUN
cblr-2960	391	5	finally	finally	ADV
cblr-2960	391	6	,	,	PUNCT
cblr-2960	391	7	there	there	PRON
cblr-2960	391	8	are	be	VERB
cblr-2960	391	9	also	also	ADV
cblr-2960	391	10	deterrent	deterrent	NOUN
cblr-2960	391	11	effects	effect	NOUN
cblr-2960	391	12	resulting	result	VERB
cblr-2960	391	13	from	from	ADP
cblr-2960	391	14	the	the	DET
cblr-2960	391	15	nature	nature	NOUN
cblr-2960	391	16	of	of	ADP
cblr-2960	391	17	private	private	ADJ
cblr-2960	391	18	placement	placement	NOUN
cblr-2960	391	19	life	life	NOUN
cblr-2960	391	20	insurance	insurance	NOUN
cblr-2960	391	21	contracts	contract	NOUN
cblr-2960	391	22	,	,	PUNCT
cblr-2960	391	23	external	external	ADJ
cblr-2960	391	24	to	to	ADP
cblr-2960	391	25	the	the	DET
cblr-2960	391	26	reforms	reform	NOUN
cblr-2960	391	27	.	.	PUNCT
cblr-2960	392	1	for	for	ADP
cblr-2960	392	2	example	example	NOUN
cblr-2960	392	3	,	,	PUNCT
cblr-2960	392	4	if	if	SCONJ
cblr-2960	392	5	the	the	DET
cblr-2960	392	6	funds	fund	NOUN
cblr-2960	392	7	within	within	ADP
cblr-2960	392	8	an	an	DET
cblr-2960	392	9	investor	investor	NOUN
cblr-2960	392	10	's	's	PART
cblr-2960	392	11	policy	policy	NOUN
cblr-2960	392	12	have	have	VERB
cblr-2960	392	13	any	any	DET
cblr-2960	392	14	losses	loss	NOUN
cblr-2960	392	15	,	,	PUNCT
cblr-2960	392	16	the	the	DET
cblr-2960	392	17	tax	tax	NOUN
cblr-2960	392	18	rules	rule	NOUN
cblr-2960	392	19	prevent	prevent	VERB
cblr-2960	392	20	investment	investment	NOUN
cblr-2960	392	21	losses	loss	NOUN
cblr-2960	392	22	within	within	ADP
cblr-2960	392	23	a	a	DET
cblr-2960	392	24	policy	policy	NOUN
cblr-2960	392	25	to	to	PART
cblr-2960	392	26	offset	offset	VERB
cblr-2960	392	27	gains	gain	NOUN
cblr-2960	392	28	outside	outside	ADP
cblr-2960	392	29	of	of	ADP
cblr-2960	392	30	the	the	DET
cblr-2960	392	31	policy.124	policy.124	NOUN
cblr-2960	392	32	direct	direct	ADJ
cblr-2960	392	33	hedge	hedge	NOUN
cblr-2960	392	34	fund	fund	NOUN
cblr-2960	392	35	investments	investment	NOUN
cblr-2960	392	36	can	can	AUX
cblr-2960	392	37	produce	produce	VERB
cblr-2960	392	38	short	short	ADJ
cblr-2960	392	39	term	term	NOUN
cblr-2960	392	40	losses	loss	NOUN
cblr-2960	392	41	that	that	PRON
cblr-2960	392	42	can	can	AUX
cblr-2960	392	43	be	be	AUX
cblr-2960	392	44	set	set	VERB
cblr-2960	392	45	against	against	ADP
cblr-2960	392	46	short	short	ADJ
cblr-2960	392	47	term	term	NOUN
cblr-2960	392	48	capital	capital	NOUN
cblr-2960	392	49	gains	gain	NOUN
cblr-2960	392	50	from	from	ADP
cblr-2960	392	51	short	short	ADJ
cblr-2960	392	52	term	term	NOUN
cblr-2960	392	53	investments	investment	NOUN
cblr-2960	392	54	or	or	CCONJ
cblr-2960	392	55	passive	passive	ADJ
cblr-2960	392	56	investments.125	investments.125	NOUN
cblr-2960	392	57	when	when	SCONJ
cblr-2960	392	58	the	the	DET
cblr-2960	392	59	taxpayer	taxpayer	NOUN
cblr-2960	392	60	has	have	VERB
cblr-2960	392	61	the	the	DET
cblr-2960	392	62	hedge	hedge	NOUN
cblr-2960	392	63	fund	fund	NOUN
cblr-2960	392	64	interest	interest	NOUN
cblr-2960	392	65	wrapped	wrap	VERB
cblr-2960	392	66	within	within	ADP
cblr-2960	392	67	a	a	DET
cblr-2960	392	68	life	life	NOUN
cblr-2960	392	69	insurance	insurance	NOUN
cblr-2960	392	70	policy	policy	NOUN
cblr-2960	392	71	,	,	PUNCT
cblr-2960	392	72	neither	neither	CCONJ
cblr-2960	392	73	gains	gain	NOUN
cblr-2960	392	74	nor	nor	CCONJ
cblr-2960	392	75	losses	loss	NOUN
cblr-2960	392	76	can	can	AUX
cblr-2960	392	77	be	be	AUX
cblr-2960	392	78	utilized	utilize	VERB
cblr-2960	392	79	for	for	ADP
cblr-2960	392	80	tax	tax	NOUN
cblr-2960	392	81	savings	saving	NOUN
cblr-2960	392	82	.	.	PUNCT
cblr-2960	393	1	furthermore	furthermore	ADV
cblr-2960	393	2	,	,	PUNCT
cblr-2960	393	3	high	high	ADJ
cblr-2960	393	4	fees	fee	NOUN
cblr-2960	393	5	also	also	ADV
cblr-2960	393	6	contribute	contribute	VERB
cblr-2960	393	7	to	to	ADP
cblr-2960	393	8	the	the	DET
cblr-2960	393	9	reason	reason	NOUN
cblr-2960	393	10	why	why	SCONJ
cblr-2960	393	11	private	private	ADJ
cblr-2960	393	12	placement	placement	NOUN
cblr-2960	393	13	life	life	NOUN
cblr-2960	393	14	insurance	insurance	NOUN
cblr-2960	393	15	contracts	contract	NOUN
cblr-2960	393	16	constitute	constitute	VERB
cblr-2960	393	17	such	such	DET
cblr-2960	393	18	a	a	DET
cblr-2960	393	19	small	small	ADJ
cblr-2960	393	20	share	share	NOUN
cblr-2960	393	21	of	of	ADP
cblr-2960	393	22	hedge	hedge	NOUN
cblr-2960	393	23	fund	fund	NOUN
cblr-2960	393	24	investments	investment	NOUN
cblr-2960	393	25	.	.	PUNCT
cblr-2960	394	1	upfront	upfront	ADJ
cblr-2960	394	2	sales	sale	NOUN
cblr-2960	394	3	charges	charge	NOUN
cblr-2960	394	4	,	,	PUNCT
cblr-2960	394	5	as	as	ADV
cblr-2960	394	6	well	well	ADV
cblr-2960	394	7	as	as	ADP
cblr-2960	394	8	state	state	NOUN
cblr-2960	394	9	premium	premium	NOUN
cblr-2960	394	10	taxes	taxis	NOUN
cblr-2960	394	11	or	or	CCONJ
cblr-2960	394	12	offshore	offshore	ADJ
cblr-2960	394	13	excise	excise	NOUN
cblr-2960	394	14	taxes	taxis	NOUN
cblr-2960	394	15	,	,	PUNCT
cblr-2960	394	16	can	can	AUX
cblr-2960	394	17	total	total	VERB
cblr-2960	394	18	about	about	ADV
cblr-2960	394	19	2.5	2.5	NUM
cblr-2960	394	20	%	%	NOUN
cblr-2960	394	21	to	to	PART
cblr-2960	394	22	4	4	NUM
cblr-2960	394	23	%	%	NOUN
cblr-2960	394	24	of	of	ADP
cblr-2960	394	25	initial	initial	ADJ
cblr-2960	394	26	premiums	premium	NOUN
cblr-2960	394	27	.	.	PUNCT
cblr-2960	395	1	'26	'26	NUM
cblr-2960	395	2	insurance	insurance	NOUN
cblr-2960	395	3	companies	company	NOUN
cblr-2960	395	4	also	also	ADV
cblr-2960	395	5	124	124	NUM
cblr-2960	395	6	see	see	VERB
cblr-2960	395	7	silverman	silverman	NOUN
cblr-2960	395	8	,	,	PUNCT
cblr-2960	395	9	supra	supra	PROPN
cblr-2960	395	10	note	note	PROPN
cblr-2960	395	11	11	11	NUM
cblr-2960	395	12	;	;	PUNCT
cblr-2960	395	13	see	see	VERB
cblr-2960	395	14	generally	generally	ADV
cblr-2960	395	15	i.r.c	i.r.c	NOUN
cblr-2960	395	16	.	.	PUNCT
cblr-2960	396	1	§	§	PROPN
cblr-2960	396	2	72	72	NUM
cblr-2960	396	3	(	(	PUNCT
cblr-2960	396	4	stating	state	VERB
cblr-2960	396	5	that	that	SCONJ
cblr-2960	396	6	gains	gain	NOUN
cblr-2960	396	7	or	or	CCONJ
cblr-2960	396	8	losses	loss	NOUN
cblr-2960	396	9	inside	inside	ADP
cblr-2960	396	10	a	a	DET
cblr-2960	396	11	life	life	NOUN
cblr-2960	396	12	insurance	insurance	NOUN
cblr-2960	396	13	policy	policy	NOUN
cblr-2960	396	14	have	have	AUX
cblr-2960	396	15	not	not	PART
cblr-2960	396	16	been	be	AUX
cblr-2960	396	17	realized	realize	VERB
cblr-2960	396	18	and	and	CCONJ
cblr-2960	396	19	can	can	AUX
cblr-2960	396	20	not	not	PART
cblr-2960	396	21	be	be	AUX
cblr-2960	396	22	used	use	VERB
cblr-2960	396	23	in	in	ADP
cblr-2960	396	24	taxable	taxable	ADJ
cblr-2960	396	25	income	income	NOUN
cblr-2960	396	26	calculations	calculation	NOUN
cblr-2960	396	27	)	)	PUNCT
cblr-2960	396	28	.	.	PUNCT
cblr-2960	397	1	15	15	NUM
cblr-2960	397	2	'	'	PART
cblr-2960	397	3	i.r.c	i.r.c	NOUN
cblr-2960	397	4	.	.	PUNCT
cblr-2960	398	1	§	§	PROPN
cblr-2960	398	2	1211	1211	NUM
cblr-2960	398	3	(	(	PUNCT
cblr-2960	398	4	providing	provide	VERB
cblr-2960	398	5	that	that	SCONJ
cblr-2960	398	6	"	"	PUNCT
cblr-2960	398	7	losses	loss	NOUN
cblr-2960	398	8	from	from	ADP
cblr-2960	398	9	sales	sale	NOUN
cblr-2960	398	10	or	or	CCONJ
cblr-2960	398	11	exchanges	exchange	NOUN
cblr-2960	398	12	of	of	ADP
cblr-2960	398	13	capital	capital	NOUN
cblr-2960	398	14	assets	asset	NOUN
cblr-2960	398	15	shall	shall	AUX
cblr-2960	398	16	be	be	AUX
cblr-2960	398	17	allowed	allow	VERB
cblr-2960	398	18	only	only	ADV
cblr-2960	398	19	to	to	ADP
cblr-2960	398	20	the	the	DET
cblr-2960	398	21	extent	extent	NOUN
cblr-2960	398	22	of	of	ADP
cblr-2960	398	23	the	the	DET
cblr-2960	398	24	gains	gain	NOUN
cblr-2960	398	25	from	from	ADP
cblr-2960	398	26	such	such	ADJ
cblr-2960	398	27	sales	sale	NOUN
cblr-2960	398	28	or	or	CCONJ
cblr-2960	398	29	exchanges	exchange	NOUN
cblr-2960	398	30	"	"	PUNCT
cblr-2960	398	31	)	)	PUNCT
cblr-2960	398	32	.	.	PUNCT
cblr-2960	399	1	12	12	NUM
cblr-2960	399	2	'	'	PUNCT
cblr-2960	399	3	see	see	PROPN
cblr-2960	399	4	schizer	schizer	NOUN
cblr-2960	399	5	,	,	PUNCT
cblr-2960	399	6	supra	supra	PROPN
cblr-2960	399	7	note	note	NOUN
cblr-2960	399	8	20	20	NUM
cblr-2960	399	9	,	,	PUNCT
cblr-2960	399	10	at	at	ADP
cblr-2960	399	11	1387	1387	NUM
cblr-2960	399	12	.	.	PUNCT
cblr-2960	400	1	col	col	PROPN
cblr-2960	400	2	umbia	umbia	PROPN
cblr-2960	400	3	b	b	PROPN
cblr-2960	400	4	usiness	usiness	PROPN
cblr-2960	400	5	la	la	PROPN
cblr-2960	400	6	w	w	PROPN
cblr-2960	400	7	re	re	PROPN
cblr-2960	400	8	vie	vie	PROPN
cblr-2960	400	9	w	w	PROPN
cblr-2960	401	1	[	[	X
cblr-2960	401	2	vol	vol	NOUN
cblr-2960	401	3	.	.	NOUN
cblr-2960	401	4	2008	2008	NUM
cblr-2960	401	5	job	job	NOUN
cblr-2960	401	6	well	well	ADV
cblr-2960	401	7	done	do	VERB
cblr-2960	401	8	charge	charge	NOUN
cblr-2960	401	9	recurring	recur	VERB
cblr-2960	401	10	fees	fee	NOUN
cblr-2960	401	11	,	,	PUNCT
cblr-2960	401	12	which	which	PRON
cblr-2960	401	13	can	can	AUX
cblr-2960	401	14	take	take	VERB
cblr-2960	401	15	a	a	DET
cblr-2960	401	16	0.25	0.25	NUM
cblr-2960	401	17	%	%	NOUN
cblr-2960	401	18	to	to	PART
cblr-2960	401	19	0.60	0.60	NUM
cblr-2960	401	20	%	%	NOUN
cblr-2960	401	21	annual	annual	ADJ
cblr-2960	401	22	bite	bite	NOUN
cblr-2960	401	23	out	out	ADP
cblr-2960	401	24	of	of	ADP
cblr-2960	401	25	the	the	DET
cblr-2960	401	26	cash	cash	NOUN
cblr-2960	401	27	value	value	NOUN
cblr-2960	401	28	of	of	ADP
cblr-2960	401	29	the	the	DET
cblr-2960	401	30	policy	policy	NOUN
cblr-2960	401	31	.	.	PUNCT
cblr-2960	402	1	127	127	NUM
cblr-2960	402	2	overall	overall	NOUN
cblr-2960	402	3	,	,	PUNCT
cblr-2960	402	4	a	a	DET
cblr-2960	402	5	policyholder	policyholder	NOUN
cblr-2960	402	6	can	can	AUX
cblr-2960	402	7	expect	expect	VERB
cblr-2960	402	8	annual	annual	ADJ
cblr-2960	402	9	fees	fee	NOUN
cblr-2960	402	10	to	to	PART
cblr-2960	402	11	average	average	VERB
cblr-2960	402	12	about	about	ADV
cblr-2960	402	13	0.75	0.75	NUM
cblr-2960	402	14	%	%	NOUN
cblr-2960	402	15	to	to	PART
cblr-2960	402	16	1.25	1.25	NUM
cblr-2960	402	17	%	%	NOUN
cblr-2960	402	18	of	of	ADP
cblr-2960	402	19	the	the	DET
cblr-2960	402	20	policy	policy	NOUN
cblr-2960	402	21	's	's	PART
cblr-2960	402	22	cash	cash	NOUN
cblr-2960	402	23	value	value	NOUN
cblr-2960	402	24	over	over	ADP
cblr-2960	402	25	the	the	DET
cblr-2960	402	26	policy	policy	NOUN
cblr-2960	402	27	's	's	PART
cblr-2960	402	28	life.128	life.128	NOUN
cblr-2960	402	29	it	it	PRON
cblr-2960	402	30	is	be	AUX
cblr-2960	402	31	worth	worth	ADJ
cblr-2960	402	32	noting	note	VERB
cblr-2960	402	33	that	that	SCONJ
cblr-2960	402	34	high	high	ADJ
cblr-2960	402	35	fees	fee	NOUN
cblr-2960	402	36	will	will	AUX
cblr-2960	402	37	cut	cut	VERB
cblr-2960	402	38	into	into	ADP
cblr-2960	402	39	the	the	DET
cblr-2960	402	40	investor	investor	NOUN
cblr-2960	402	41	's	's	PART
cblr-2960	402	42	tax	tax	NOUN
cblr-2960	402	43	benefit	benefit	NOUN
cblr-2960	402	44	and	and	CCONJ
cblr-2960	402	45	lower	low	ADJ
cblr-2960	402	46	the	the	DET
cblr-2960	402	47	overall	overall	ADJ
cblr-2960	402	48	yield	yield	NOUN
cblr-2960	402	49	on	on	ADP
cblr-2960	402	50	the	the	DET
cblr-2960	402	51	investment	investment	NOUN
cblr-2960	402	52	.	.	PUNCT
cblr-2960	403	1	129	129	NUM
cblr-2960	403	2	in	in	ADP
cblr-2960	403	3	addition	addition	NOUN
cblr-2960	403	4	,	,	PUNCT
cblr-2960	403	5	the	the	DET
cblr-2960	403	6	carried	carry	VERB
cblr-2960	403	7	interest	interest	NOUN
cblr-2960	403	8	problem	problem	NOUN
cblr-2960	403	9	caused	cause	VERB
cblr-2960	403	10	by	by	ADP
cblr-2960	403	11	the	the	DET
cblr-2960	403	12	regulations	regulation	NOUN
cblr-2960	403	13	of	of	ADP
cblr-2960	403	14	section	section	NOUN
cblr-2960	403	15	817	817	NUM
cblr-2960	403	16	has	have	AUX
cblr-2960	403	17	eliminated	eliminate	VERB
cblr-2960	403	18	the	the	DET
cblr-2960	403	19	use	use	NOUN
cblr-2960	403	20	of	of	ADP
cblr-2960	403	21	some	some	DET
cblr-2960	403	22	insurance	insurance	NOUN
cblr-2960	403	23	wrappers	wrapper	NOUN
cblr-2960	403	24	as	as	ADP
cblr-2960	403	25	alternatives	alternative	NOUN
cblr-2960	403	26	to	to	ADP
cblr-2960	403	27	direct	direct	ADJ
cblr-2960	403	28	hedge	hedge	NOUN
cblr-2960	403	29	fund	fund	NOUN
cblr-2960	403	30	investment	investment	NOUN
cblr-2960	403	31	.	.	PUNCT
cblr-2960	404	1	typically	typically	ADV
cblr-2960	404	2	,	,	PUNCT
cblr-2960	404	3	a	a	DET
cblr-2960	404	4	carried	carry	VERB
cblr-2960	404	5	interest	interest	NOUN
cblr-2960	404	6	in	in	ADP
cblr-2960	404	7	a	a	DET
cblr-2960	404	8	hedge	hedge	NOUN
cblr-2960	404	9	fund	fund	NOUN
cblr-2960	404	10	will	will	AUX
cblr-2960	404	11	convey	convey	VERB
cblr-2960	404	12	20	20	NUM
cblr-2960	404	13	%	%	NOUN
cblr-2960	404	14	of	of	ADP
cblr-2960	404	15	the	the	DET
cblr-2960	404	16	portfolio	portfolio	NOUN
cblr-2960	404	17	gains	gain	NOUN
cblr-2960	404	18	to	to	ADP
cblr-2960	404	19	the	the	DET
cblr-2960	404	20	general	general	ADJ
cblr-2960	404	21	partner	partner	NOUN
cblr-2960	404	22	as	as	ADP
cblr-2960	404	23	compensation	compensation	NOUN
cblr-2960	404	24	for	for	ADP
cblr-2960	404	25	his	his	PRON
cblr-2960	404	26	services	service	NOUN
cblr-2960	404	27	.	.	PUNCT
cblr-2960	405	1	3	3	NUM
cblr-2960	405	2	°	°	NOUN
cblr-2960	405	3	the	the	DET
cblr-2960	405	4	regulation	regulation	NOUN
cblr-2960	405	5	provides	provide	VERB
cblr-2960	405	6	that	that	SCONJ
cblr-2960	405	7	life	life	NOUN
cblr-2960	405	8	insurance	insurance	NOUN
cblr-2960	405	9	companies	company	NOUN
cblr-2960	405	10	are	be	AUX
cblr-2960	405	11	permitted	permit	VERB
cblr-2960	405	12	to	to	PART
cblr-2960	405	13	disregard	disregard	VERB
cblr-2960	405	14	the	the	DET
cblr-2960	405	15	equity	equity	NOUN
cblr-2960	405	16	of	of	ADP
cblr-2960	405	17	the	the	DET
cblr-2960	405	18	portfolio	portfolio	NOUN
cblr-2960	405	19	manager	manager	NOUN
cblr-2960	405	20	as	as	ADP
cblr-2960	405	21	an	an	DET
cblr-2960	405	22	interest	interest	NOUN
cblr-2960	405	23	available	available	ADJ
cblr-2960	405	24	to	to	ADP
cblr-2960	405	25	the	the	DET
cblr-2960	405	26	public	public	NOUN
cblr-2960	405	27	only	only	ADV
cblr-2960	405	28	if	if	SCONJ
cblr-2960	405	29	the	the	DET
cblr-2960	405	30	return	return	NOUN
cblr-2960	405	31	on	on	ADP
cblr-2960	405	32	such	such	ADJ
cblr-2960	405	33	equity	equity	NOUN
cblr-2960	405	34	is	be	AUX
cblr-2960	405	35	calculated	calculate	VERB
cblr-2960	405	36	in	in	ADP
cblr-2960	405	37	the	the	DET
cblr-2960	405	38	same	same	ADJ
cblr-2960	405	39	manner	manner	NOUN
cblr-2960	405	40	as	as	ADP
cblr-2960	405	41	the	the	DET
cblr-2960	405	42	return	return	NOUN
cblr-2960	405	43	on	on	ADP
cblr-2960	405	44	interests	interest	NOUN
cblr-2960	405	45	in	in	ADP
cblr-2960	405	46	a	a	DET
cblr-2960	405	47	segregated	segregated	ADJ
cblr-2960	405	48	asset	asset	NOUN
cblr-2960	405	49	account	account	NOUN
cblr-2960	405	50	.	.	PUNCT
cblr-2960	406	1	31	31	NUM
cblr-2960	407	1	if	if	SCONJ
cblr-2960	407	2	the	the	DET
cblr-2960	407	3	fund	fund	NOUN
cblr-2960	407	4	manager	manager	NOUN
cblr-2960	407	5	retains	retain	VERB
cblr-2960	407	6	a	a	DET
cblr-2960	407	7	carried	carried	ADJ
cblr-2960	407	8	interest	interest	NOUN
cblr-2960	407	9	that	that	PRON
cblr-2960	407	10	differs	differ	VERB
cblr-2960	407	11	from	from	ADP
cblr-2960	407	12	the	the	DET
cblr-2960	407	13	economic	economic	ADJ
cblr-2960	407	14	terms	term	NOUN
cblr-2960	407	15	of	of	ADP
cblr-2960	407	16	the	the	DET
cblr-2960	407	17	hedge	hedge	NOUN
cblr-2960	407	18	fund	fund	PROPN
cblr-2960	407	19	interest	interest	NOUN
cblr-2960	407	20	,	,	PUNCT
cblr-2960	407	21	look	look	VERB
cblr-2960	407	22	-	-	PUNCT
cblr-2960	407	23	through	through	ADP
cblr-2960	407	24	treatment	treatment	NOUN
cblr-2960	407	25	under	under	ADP
cblr-2960	407	26	section	section	NOUN
cblr-2960	407	27	817	817	NUM
cblr-2960	407	28	is	be	AUX
cblr-2960	407	29	denied	deny	VERB
cblr-2960	407	30	.	.	PUNCT
cblr-2960	408	1	2	2	NUM
cblr-2960	408	2	however	however	ADV
cblr-2960	408	3	,	,	PUNCT
cblr-2960	408	4	the	the	DET
cblr-2960	408	5	fund	fund	NOUN
cblr-2960	408	6	manager	manager	NOUN
cblr-2960	408	7	can	can	AUX
cblr-2960	408	8	still	still	ADV
cblr-2960	408	9	participate	participate	VERB
cblr-2960	408	10	if	if	SCONJ
cblr-2960	408	11	he	he	PRON
cblr-2960	408	12	receives	receive	VERB
cblr-2960	408	13	the	the	DET
cblr-2960	408	14	20	20	NUM
cblr-2960	408	15	%	%	NOUN
cblr-2960	408	16	carry	carry	NOUN
cblr-2960	408	17	as	as	ADP
cblr-2960	408	18	a	a	DET
cblr-2960	408	19	fee	fee	NOUN
cblr-2960	408	20	for	for	ADP
cblr-2960	408	21	services	service	NOUN
cblr-2960	408	22	rather	rather	ADV
cblr-2960	408	23	than	than	ADP
cblr-2960	408	24	as	as	ADP
cblr-2960	408	25	an	an	DET
cblr-2960	408	26	equity	equity	NOUN
cblr-2960	408	27	interest	interest	NOUN
cblr-2960	408	28	in	in	ADP
cblr-2960	408	29	the	the	DET
cblr-2960	408	30	fund	fund	NOUN
cblr-2960	408	31	.	.	PUNCT
cblr-2960	409	1	3	3	NUM
cblr-2960	409	2	in	in	ADP
cblr-2960	409	3	this	this	DET
cblr-2960	409	4	case	case	NOUN
cblr-2960	409	5	,	,	PUNCT
cblr-2960	409	6	the	the	DET
cblr-2960	409	7	carry	carry	NOUN
cblr-2960	409	8	will	will	AUX
cblr-2960	409	9	generate	generate	VERB
cblr-2960	409	10	taxable	taxable	ADJ
cblr-2960	409	11	compensation	compensation	NOUN
cblr-2960	409	12	income	income	NOUN
cblr-2960	409	13	rather	rather	ADV
cblr-2960	409	14	than	than	ADP
cblr-2960	409	15	capital	capital	NOUN
cblr-2960	409	16	gain	gain	NOUN
cblr-2960	409	17	.	.	PUNCT
cblr-2960	410	1	3	3	NUM
cblr-2960	410	2	1	1	NUM
cblr-2960	410	3	it	it	PRON
cblr-2960	410	4	is	be	AUX
cblr-2960	410	5	significant	significant	ADJ
cblr-2960	410	6	that	that	SCONJ
cblr-2960	410	7	a	a	DET
cblr-2960	410	8	fund	fund	NOUN
cblr-2960	410	9	manager	manager	NOUN
cblr-2960	410	10	that	that	PRON
cblr-2960	410	11	chooses	choose	VERB
cblr-2960	410	12	to	to	PART
cblr-2960	410	13	retain	retain	VERB
cblr-2960	410	14	a	a	DET
cblr-2960	410	15	20	20	NUM
cblr-2960	410	16	%	%	NOUN
cblr-2960	410	17	equity	equity	NOUN
cblr-2960	410	18	interest	interest	NOUN
cblr-2960	410	19	in	in	ADP
cblr-2960	410	20	the	the	DET
cblr-2960	410	21	fund	fund	NOUN
cblr-2960	410	22	will	will	AUX
cblr-2960	410	23	preclude	preclude	VERB
cblr-2960	410	24	the	the	DET
cblr-2960	410	25	fund	fund	NOUN
cblr-2960	410	26	from	from	ADP
cblr-2960	410	27	being	be	AUX
cblr-2960	410	28	used	use	VERB
cblr-2960	410	29	in	in	ADP
cblr-2960	410	30	an	an	DET
cblr-2960	410	31	insurance	insurance	NOUN
cblr-2960	410	32	wrapper	wrapper	NOUN
cblr-2960	410	33	.	.	PUNCT
cblr-2960	411	1	thus	thus	ADV
cblr-2960	411	2	,	,	PUNCT
cblr-2960	411	3	even	even	ADV
cblr-2960	411	4	if	if	SCONJ
cblr-2960	411	5	the	the	DET
cblr-2960	411	6	hedge	hedge	NOUN
cblr-2960	411	7	fund	fund	NOUN
cblr-2960	411	8	is	be	AUX
cblr-2960	411	9	insurance	insurance	NOUN
cblr-2960	411	10	-	-	PUNCT
cblr-2960	411	11	dedicated	dedicate	VERB
cblr-2960	411	12	,	,	PUNCT
cblr-2960	411	13	a	a	DET
cblr-2960	411	14	hedge	hedge	NOUN
cblr-2960	411	15	fund	fund	NOUN
cblr-2960	411	16	with	with	ADP
cblr-2960	411	17	a	a	DET
cblr-2960	411	18	carried	carry	VERB
cblr-2960	411	19	interest	interest	NOUN
cblr-2960	411	20	may	may	AUX
cblr-2960	411	21	not	not	PART
cblr-2960	411	22	qualify	qualify	VERB
cblr-2960	411	23	for	for	ADP
cblr-2960	411	24	look	look	VERB
cblr-2960	411	25	-	-	PUNCT
cblr-2960	411	26	through	through	ADP
cblr-2960	411	27	treatment	treatment	NOUN
cblr-2960	411	28	under	under	ADP
cblr-2960	411	29	the	the	DET
cblr-2960	411	30	diversification	diversification	NOUN
cblr-2960	411	31	rules	rule	NOUN
cblr-2960	411	32	.	.	PUNCT
cblr-2960	412	1	127	127	NUM
cblr-2960	412	2	see	see	VERB
cblr-2960	412	3	silverman	silverman	NOUN
cblr-2960	412	4	,	,	PUNCT
cblr-2960	412	5	supra	supra	PROPN
cblr-2960	412	6	note	note	PROPN
cblr-2960	412	7	11	11	NUM
cblr-2960	412	8	.	.	NUM
cblr-2960	412	9	128	128	NUM
cblr-2960	413	1	i	i	NOUN
cblr-2960	413	2	d.	d.	PROPN
cblr-2960	413	3	129	129	NUM
cblr-2960	413	4	see	see	VERB
cblr-2960	413	5	luke	luke	PROPN
cblr-2960	413	6	,	,	PUNCT
cblr-2960	413	7	supra	supra	PROPN
cblr-2960	413	8	note	note	NOUN
cblr-2960	413	9	3	3	NUM
cblr-2960	413	10	,	,	PUNCT
cblr-2960	413	11	at	at	ADP
cblr-2960	413	12	186	186	NUM
cblr-2960	413	13	.	.	PUNCT
cblr-2960	414	1	see	see	VERB
cblr-2960	414	2	needham	needham	PROPN
cblr-2960	414	3	&	&	CCONJ
cblr-2960	414	4	brause	brause	PROPN
cblr-2960	414	5	,	,	PUNCT
cblr-2960	414	6	supra	supra	PROPN
cblr-2960	414	7	note	note	PROPN
cblr-2960	414	8	53	53	NUM
cblr-2960	414	9	,	,	PUNCT
cblr-2960	414	10	at	at	ADP
cblr-2960	414	11	a-101	a-101	PROPN
cblr-2960	414	12	.	.	PUNCT
cblr-2960	415	1	131	131	NUM
cblr-2960	415	2	see	see	VERB
cblr-2960	415	3	treas	treas	PROPN
cblr-2960	415	4	.	.	PUNCT
cblr-2960	416	1	reg	reg	PROPN
cblr-2960	416	2	.	.	PUNCT
cblr-2960	417	1	§	§	PROPN
cblr-2960	417	2	1.817	1.817	NUM
cblr-2960	417	3	-	-	SYM
cblr-2960	417	4	5(f)(3)(ii	5(f)(3)(ii	NUM
cblr-2960	417	5	)	)	PUNCT
cblr-2960	417	6	(	(	PUNCT
cblr-2960	417	7	2003	2003	NUM
cblr-2960	417	8	)	)	PUNCT
cblr-2960	417	9	;	;	PUNCT
cblr-2960	417	10	see	see	VERB
cblr-2960	417	11	also	also	ADV
cblr-2960	417	12	needham	needham	PROPN
cblr-2960	417	13	&	&	CCONJ
cblr-2960	417	14	brause	brause	PROPN
cblr-2960	417	15	,	,	PUNCT
cblr-2960	417	16	supra	supra	PROPN
cblr-2960	417	17	note	note	NOUN
cblr-2960	417	18	53	53	NUM
cblr-2960	417	19	.	.	PUNCT
cblr-2960	418	1	132	132	NUM
cblr-2960	418	2	see	see	VERB
cblr-2960	418	3	treas	treas	PROPN
cblr-2960	418	4	.	.	PUNCT
cblr-2960	419	1	reg	reg	PROPN
cblr-2960	419	2	.	.	PUNCT
cblr-2960	420	1	§	§	PROPN
cblr-2960	420	2	1.817	1.817	NUM
cblr-2960	420	3	-	-	SYM
cblr-2960	420	4	5(f)(3)(ii	5(f)(3)(ii	NUM
cblr-2960	420	5	)	)	PUNCT
cblr-2960	420	6	(	(	PUNCT
cblr-2960	420	7	2003	2003	NUM
cblr-2960	420	8	)	)	PUNCT
cblr-2960	420	9	.	.	PUNCT
cblr-2960	420	10	'	'	PUNCT
cblr-2960	421	1	see	see	VERB
cblr-2960	421	2	needham	needham	PROPN
cblr-2960	421	3	&	&	CCONJ
cblr-2960	421	4	brause	brause	PROPN
cblr-2960	421	5	,	,	PUNCT
cblr-2960	421	6	supra	supra	PROPN
cblr-2960	421	7	note	note	PROPN
cblr-2960	421	8	53	53	NUM
cblr-2960	421	9	,	,	PUNCT
cblr-2960	421	10	at	at	ADP
cblr-2960	421	11	a-101	a-101	PROPN
cblr-2960	421	12	.	.	PUNCT
cblr-2960	422	1	134	134	NUM
cblr-2960	422	2	see	see	NOUN
cblr-2960	422	3	i.r.c	i.r.c	NOUN
cblr-2960	422	4	.	.	PUNCT
cblr-2960	423	1	§	§	PROPN
cblr-2960	423	2	61	61	NUM
cblr-2960	423	3	.	.	PUNCT
cblr-2960	424	1	no	no	INTJ
cblr-2960	424	2	.	.	PUNCT
cblr-2960	425	1	2:694	2:694	NUM
cblr-2960	425	2	]	]	X
cblr-2960	425	3	b.	b.	NOUN
cblr-2960	425	4	tiny	tiny	ADJ
cblr-2960	425	5	fraction	fraction	NOUN
cblr-2960	425	6	of	of	ADP
cblr-2960	425	7	the	the	DET
cblr-2960	425	8	market	market	NOUN
cblr-2960	425	9	the	the	DET
cblr-2960	425	10	trend	trend	NOUN
cblr-2960	425	11	in	in	ADP
cblr-2960	425	12	the	the	DET
cblr-2960	425	13	market	market	NOUN
cblr-2960	425	14	suggests	suggest	VERB
cblr-2960	425	15	that	that	SCONJ
cblr-2960	425	16	the	the	DET
cblr-2960	425	17	increased	increase	VERB
cblr-2960	425	18	frictions	friction	NOUN
cblr-2960	425	19	attributable	attributable	ADJ
cblr-2960	425	20	to	to	ADP
cblr-2960	425	21	the	the	DET
cblr-2960	425	22	tax	tax	NOUN
cblr-2960	425	23	rules	rule	NOUN
cblr-2960	425	24	have	have	AUX
cblr-2960	425	25	been	be	AUX
cblr-2960	425	26	successful	successful	ADJ
cblr-2960	425	27	in	in	ADP
cblr-2960	425	28	deterring	deter	VERB
cblr-2960	425	29	the	the	DET
cblr-2960	425	30	use	use	NOUN
cblr-2960	425	31	of	of	ADP
cblr-2960	425	32	private	private	ADJ
cblr-2960	425	33	placement	placement	NOUN
cblr-2960	425	34	life	life	NOUN
cblr-2960	425	35	insurance	insurance	NOUN
cblr-2960	425	36	contracts	contract	NOUN
cblr-2960	425	37	.	.	PUNCT
cblr-2960	426	1	while	while	SCONJ
cblr-2960	426	2	private	private	ADJ
cblr-2960	426	3	placement	placement	NOUN
cblr-2960	426	4	life	life	NOUN
cblr-2960	426	5	insurance	insurance	NOUN
cblr-2960	426	6	policies	policy	NOUN
cblr-2960	426	7	continue	continue	VERB
cblr-2960	426	8	to	to	PART
cblr-2960	426	9	be	be	AUX
cblr-2960	426	10	offered	offer	VERB
cblr-2960	426	11	by	by	ADP
cblr-2960	426	12	major	major	ADJ
cblr-2960	426	13	insurance	insurance	NOUN
cblr-2960	426	14	companies	company	NOUN
cblr-2960	426	15	,	,	PUNCT
cblr-2960	426	16	these	these	DET
cblr-2960	426	17	investments	investment	NOUN
cblr-2960	426	18	represent	represent	VERB
cblr-2960	426	19	an	an	DET
cblr-2960	426	20	insignificant	insignificant	ADJ
cblr-2960	426	21	amount	amount	NOUN
cblr-2960	426	22	of	of	ADP
cblr-2960	426	23	total	total	ADJ
cblr-2960	426	24	investment	investment	NOUN
cblr-2960	426	25	in	in	ADP
cblr-2960	426	26	the	the	DET
cblr-2960	426	27	hedge	hedge	NOUN
cblr-2960	426	28	fund	fund	NOUN
cblr-2960	426	29	industry	industry	NOUN
cblr-2960	426	30	.	.	PUNCT
cblr-2960	427	1	in	in	ADP
cblr-2960	427	2	2006	2006	NUM
cblr-2960	427	3	,	,	PUNCT
cblr-2960	427	4	the	the	DET
cblr-2960	427	5	total	total	ADJ
cblr-2960	427	6	amount	amount	NOUN
cblr-2960	427	7	invested	invest	VERB
cblr-2960	427	8	in	in	ADP
cblr-2960	427	9	hedge	hedge	NOUN
cblr-2960	427	10	funds	fund	NOUN
cblr-2960	427	11	was	be	AUX
cblr-2960	427	12	$	$	SYM
cblr-2960	427	13	1.23	1.23	NUM
cblr-2960	427	14	trillion.13	trillion.13	NUM
cblr-2960	427	15	nevertheless	nevertheless	ADV
cblr-2960	427	16	,	,	PUNCT
cblr-2960	427	17	industry	industry	NOUN
cblr-2960	427	18	watchers	watcher	NOUN
cblr-2960	427	19	estimated	estimate	VERB
cblr-2960	427	20	that	that	SCONJ
cblr-2960	427	21	the	the	DET
cblr-2960	427	22	total	total	ADJ
cblr-2960	427	23	onshore	onshore	ADJ
cblr-2960	427	24	individual	individual	ADJ
cblr-2960	427	25	private	private	ADJ
cblr-2960	427	26	placement	placement	NOUN
cblr-2960	427	27	life	life	NOUN
cblr-2960	427	28	insurance	insurance	NOUN
cblr-2960	427	29	and	and	CCONJ
cblr-2960	427	30	annuity	annuity	NOUN
cblr-2960	427	31	market	market	NOUN
cblr-2960	427	32	was	be	AUX
cblr-2960	427	33	about	about	ADV
cblr-2960	427	34	$	$	SYM
cblr-2960	427	35	4	4	NUM
cblr-2960	427	36	to	to	PART
cblr-2960	427	37	$	$	SYM
cblr-2960	427	38	5	5	NUM
cblr-2960	427	39	billion	billion	NUM
cblr-2960	427	40	in	in	ADP
cblr-2960	427	41	2006.136	2006.136	PROPN
cblr-2960	427	42	therefore	therefore	ADV
cblr-2960	427	43	,	,	PUNCT
cblr-2960	427	44	private	private	ADJ
cblr-2960	427	45	placement	placement	NOUN
cblr-2960	427	46	life	life	NOUN
cblr-2960	427	47	insurance	insurance	NOUN
cblr-2960	427	48	contracts	contract	NOUN
cblr-2960	427	49	constituted	constitute	VERB
cblr-2960	427	50	less	less	ADJ
cblr-2960	427	51	than	than	ADP
cblr-2960	427	52	half	half	NOUN
cblr-2960	427	53	of	of	ADP
cblr-2960	427	54	one	one	NUM
cblr-2960	427	55	percent	percent	NOUN
cblr-2960	427	56	of	of	ADP
cblr-2960	427	57	the	the	DET
cblr-2960	427	58	total	total	ADJ
cblr-2960	427	59	value	value	NOUN
cblr-2960	427	60	invested	invest	VERB
cblr-2960	427	61	in	in	ADP
cblr-2960	427	62	hedge	hedge	NOUN
cblr-2960	427	63	funds	fund	NOUN
cblr-2960	427	64	.	.	PUNCT
cblr-2960	428	1	with	with	ADP
cblr-2960	428	2	the	the	DET
cblr-2960	428	3	private	private	ADJ
cblr-2960	428	4	placement	placement	NOUN
cblr-2960	428	5	life	life	NOUN
cblr-2960	428	6	insurance	insurance	NOUN
cblr-2960	428	7	market	market	NOUN
cblr-2960	428	8	representing	represent	VERB
cblr-2960	428	9	such	such	DET
cblr-2960	428	10	a	a	DET
cblr-2960	428	11	small	small	ADJ
cblr-2960	428	12	portion	portion	NOUN
cblr-2960	428	13	of	of	ADP
cblr-2960	428	14	the	the	DET
cblr-2960	428	15	total	total	ADJ
cblr-2960	428	16	value	value	NOUN
cblr-2960	428	17	of	of	ADP
cblr-2960	428	18	hedge	hedge	NOUN
cblr-2960	428	19	fund	fund	NOUN
cblr-2960	428	20	investments	investment	NOUN
cblr-2960	428	21	,	,	PUNCT
cblr-2960	428	22	it	it	PRON
cblr-2960	428	23	appears	appear	VERB
cblr-2960	428	24	that	that	SCONJ
cblr-2960	428	25	the	the	DET
cblr-2960	428	26	irs	irs	PROPN
cblr-2960	428	27	's	's	PART
cblr-2960	428	28	objective	objective	NOUN
cblr-2960	428	29	of	of	ADP
cblr-2960	428	30	preventing	prevent	VERB
cblr-2960	428	31	widespread	widespread	ADJ
cblr-2960	428	32	abuse	abuse	NOUN
cblr-2960	428	33	was	be	AUX
cblr-2960	428	34	accomplished	accomplish	VERB
cblr-2960	428	35	.	.	PUNCT
cblr-2960	429	1	vi	vi	X
cblr-2960	429	2	.	.	PROPN
cblr-2960	429	3	conclusion	conclusion	NOUN
cblr-2960	429	4	investors	investor	NOUN
cblr-2960	429	5	may	may	AUX
cblr-2960	429	6	use	use	VERB
cblr-2960	429	7	private	private	ADJ
cblr-2960	429	8	placement	placement	NOUN
cblr-2960	429	9	life	life	NOUN
cblr-2960	429	10	insurance	insurance	NOUN
cblr-2960	429	11	contracts	contract	NOUN
cblr-2960	429	12	to	to	PART
cblr-2960	429	13	wrap	wrap	VERB
cblr-2960	429	14	hedge	hedge	NOUN
cblr-2960	429	15	fund	fund	NOUN
cblr-2960	429	16	investments	investment	NOUN
cblr-2960	429	17	and	and	CCONJ
cblr-2960	429	18	defer	defer	VERB
cblr-2960	429	19	tax	tax	NOUN
cblr-2960	429	20	on	on	ADP
cblr-2960	429	21	gains	gain	NOUN
cblr-2960	429	22	held	hold	VERB
cblr-2960	429	23	within	within	ADP
cblr-2960	429	24	the	the	DET
cblr-2960	429	25	insurance	insurance	NOUN
cblr-2960	429	26	policy	policy	NOUN
cblr-2960	429	27	.	.	PUNCT
cblr-2960	430	1	in	in	ADP
cblr-2960	430	2	order	order	NOUN
cblr-2960	430	3	to	to	PART
cblr-2960	430	4	"	"	PUNCT
cblr-2960	430	5	prevent	prevent	VERB
cblr-2960	430	6	taxpayers	taxpayer	NOUN
cblr-2960	430	7	from	from	ADP
cblr-2960	430	8	turning	turn	VERB
cblr-2960	430	9	otherwise	otherwise	ADV
cblr-2960	430	10	taxable	taxable	ADJ
cblr-2960	430	11	investments	investment	NOUN
cblr-2960	430	12	in	in	ADP
cblr-2960	430	13	hedge	hedge	NOUN
cblr-2960	430	14	funds	fund	NOUN
cblr-2960	430	15	..	..	PUNCT
cblr-2960	430	16	.	.	PUNCT
cblr-2960	431	1	into	into	ADP
cblr-2960	431	2	tax	tax	NOUN
cblr-2960	431	3	-	-	PUNCT
cblr-2960	431	4	deferred	defer	VERB
cblr-2960	431	5	or	or	CCONJ
cblr-2960	431	6	tax	tax	NOUN
cblr-2960	431	7	-	-	PUNCT
cblr-2960	431	8	free	free	ADJ
cblr-2960	431	9	investments	investment	NOUN
cblr-2960	431	10	merely	merely	ADV
cblr-2960	431	11	by	by	ADP
cblr-2960	431	12	purchasing	purchase	VERB
cblr-2960	431	13	the	the	DET
cblr-2960	431	14	investments	investment	NOUN
cblr-2960	431	15	through	through	ADP
cblr-2960	431	16	a	a	DET
cblr-2960	431	17	life	life	NOUN
cblr-2960	431	18	insurance	insurance	NOUN
cblr-2960	431	19	.	.	PUNCT
cblr-2960	431	20	.	.	PUNCT
cblr-2960	432	1	.	.	PUNCT
cblr-2960	433	1	contract	contract	NOUN
cblr-2960	433	2	,	,	PUNCT
cblr-2960	433	3	"	"	PUNCT
cblr-2960	433	4	the	the	DET
cblr-2960	433	5	tax	tax	NOUN
cblr-2960	433	6	agencies	agency	NOUN
cblr-2960	433	7	implemented	implement	VERB
cblr-2960	433	8	specific	specific	ADJ
cblr-2960	433	9	reforms	reform	NOUN
cblr-2960	433	10	.	.	PUNCT
cblr-2960	434	1	'37	'37	NUM
cblr-2960	434	2	by	by	ADP
cblr-2960	434	3	2005	2005	NUM
cblr-2960	434	4	,	,	PUNCT
cblr-2960	434	5	when	when	SCONJ
cblr-2960	434	6	the	the	DET
cblr-2960	434	7	last	last	ADJ
cblr-2960	434	8	changes	change	NOUN
cblr-2960	434	9	were	be	AUX
cblr-2960	434	10	finalized	finalize	VERB
cblr-2960	434	11	,	,	PUNCT
cblr-2960	434	12	investors	investor	NOUN
cblr-2960	434	13	,	,	PUNCT
cblr-2960	434	14	life	life	NOUN
cblr-2960	434	15	insurance	insurance	NOUN
cblr-2960	434	16	companies	company	NOUN
cblr-2960	434	17	,	,	PUNCT
cblr-2960	434	18	and	and	CCONJ
cblr-2960	434	19	hedge	hedge	NOUN
cblr-2960	434	20	fund	fund	NOUN
cblr-2960	434	21	managers	manager	NOUN
cblr-2960	434	22	had	have	VERB
cblr-2960	434	23	a	a	DET
cblr-2960	434	24	clear	clear	ADJ
cblr-2960	434	25	roadmap	roadmap	NOUN
cblr-2960	434	26	of	of	ADP
cblr-2960	434	27	how	how	SCONJ
cblr-2960	434	28	to	to	PART
cblr-2960	434	29	successfully	successfully	ADV
cblr-2960	434	30	structure	structure	VERB
cblr-2960	434	31	policies	policy	NOUN
cblr-2960	434	32	to	to	PART
cblr-2960	434	33	achieve	achieve	VERB
cblr-2960	434	34	a	a	DET
cblr-2960	434	35	tax	tax	NOUN
cblr-2960	434	36	-	-	PUNCT
cblr-2960	434	37	free	free	ADJ
cblr-2960	434	38	investment	investment	NOUN
cblr-2960	434	39	.	.	PUNCT
cblr-2960	435	1	the	the	DET
cblr-2960	435	2	tax	tax	NOUN
cblr-2960	435	3	reforms	reform	NOUN
cblr-2960	435	4	that	that	PRON
cblr-2960	435	5	enacted	enact	VERB
cblr-2960	435	6	the	the	DET
cblr-2960	435	7	diversification	diversification	NOUN
cblr-2960	435	8	requirement	requirement	NOUN
cblr-2960	435	9	and	and	CCONJ
cblr-2960	435	10	established	establish	VERB
cblr-2960	435	11	the	the	DET
cblr-2960	435	12	investor	investor	NOUN
cblr-2960	435	13	control	control	NOUN
cblr-2960	435	14	doctrine	doctrine	NOUN
cblr-2960	435	15	,	,	PUNCT
cblr-2960	435	16	however	however	ADV
cblr-2960	435	17	,	,	PUNCT
cblr-2960	435	18	proved	prove	VERB
cblr-2960	435	19	to	to	ADP
cblr-2960	435	20	135	135	NUM
cblr-2960	435	21	silverman	silverman	NOUN
cblr-2960	435	22	,	,	PUNCT
cblr-2960	435	23	supra	supra	PROPN
cblr-2960	435	24	note	note	PROPN
cblr-2960	435	25	11	11	NUM
cblr-2960	435	26	.	.	X
cblr-2960	436	1	136	136	NUM
cblr-2960	437	1	i	i	PRON
cblr-2960	437	2	d.	d.	PROPN
cblr-2960	437	3	37	37	NUM
cblr-2960	437	4	internal	internal	ADJ
cblr-2960	437	5	revenue	revenue	NOUN
cblr-2960	437	6	serv	serv	X
cblr-2960	437	7	.	.	PUNCT
cblr-2960	437	8	,	,	PUNCT
cblr-2960	437	9	supra	supra	PROPN
cblr-2960	437	10	note	note	NOUN
cblr-2960	437	11	71	71	NUM
cblr-2960	437	12	.	.	PUNCT
cblr-2960	438	1	col	col	PROPN
cblr-2960	438	2	umia	umia	PROPN
cblr-2960	438	3	b	b	PROPN
cblr-2960	438	4	usiness	usiness	PROPN
cblr-2960	438	5	la	la	PROPN
cblr-2960	438	6	w	w	PROPN
cblr-2960	438	7	re	re	PROPN
cblr-2960	438	8	vie	vie	PROPN
cblr-2960	438	9	w	w	PROPN
cblr-2960	439	1	[	[	X
cblr-2960	439	2	vol	vol	NOUN
cblr-2960	439	3	.	.	NOUN
cblr-2960	439	4	2008722	2008722	NUM
cblr-2960	439	5	job	job	NOUN
cblr-2960	439	6	well	well	ADV
cblr-2960	439	7	done	done	AUX
cblr-2960	439	8	be	be	AUX
cblr-2960	439	9	effective	effective	ADJ
cblr-2960	439	10	measures	measure	NOUN
cblr-2960	439	11	against	against	ADP
cblr-2960	439	12	private	private	ADJ
cblr-2960	439	13	placement	placement	NOUN
cblr-2960	439	14	life	life	NOUN
cblr-2960	439	15	insurance	insurance	NOUN
cblr-2960	439	16	wrappers	wrapper	NOUN
cblr-2960	439	17	.	.	PUNCT
cblr-2960	440	1	the	the	DET
cblr-2960	440	2	loss	loss	NOUN
cblr-2960	440	3	of	of	ADP
cblr-2960	440	4	control	control	NOUN
cblr-2960	440	5	over	over	ADP
cblr-2960	440	6	the	the	DET
cblr-2960	440	7	underlying	underlie	VERB
cblr-2960	440	8	investments	investment	NOUN
cblr-2960	440	9	in	in	ADP
cblr-2960	440	10	the	the	DET
cblr-2960	440	11	life	life	NOUN
cblr-2960	440	12	insurance	insurance	NOUN
cblr-2960	440	13	policy	policy	NOUN
cblr-2960	440	14	,	,	PUNCT
cblr-2960	440	15	reluctance	reluctance	NOUN
cblr-2960	440	16	to	to	PART
cblr-2960	440	17	set	set	VERB
cblr-2960	440	18	up	up	ADP
cblr-2960	440	19	compliant	compliant	ADJ
cblr-2960	440	20	funds	fund	NOUN
cblr-2960	440	21	and	and	CCONJ
cblr-2960	440	22	policies	policy	NOUN
cblr-2960	440	23	,	,	PUNCT
cblr-2960	440	24	and	and	CCONJ
cblr-2960	440	25	the	the	DET
cblr-2960	440	26	increased	increase	VERB
cblr-2960	440	27	costs	cost	NOUN
cblr-2960	440	28	of	of	ADP
cblr-2960	440	29	compliance	compliance	NOUN
cblr-2960	440	30	with	with	ADP
cblr-2960	440	31	the	the	DET
cblr-2960	440	32	tax	tax	NOUN
cblr-2960	440	33	rules	rule	NOUN
cblr-2960	440	34	have	have	AUX
cblr-2960	440	35	collectively	collectively	ADV
cblr-2960	440	36	increased	increase	VERB
cblr-2960	440	37	the	the	DET
cblr-2960	440	38	frictions	friction	NOUN
cblr-2960	440	39	against	against	ADP
cblr-2960	440	40	private	private	ADJ
cblr-2960	440	41	placement	placement	NOUN
cblr-2960	440	42	life	life	NOUN
cblr-2960	440	43	insurance	insurance	NOUN
cblr-2960	440	44	as	as	ADP
cblr-2960	440	45	a	a	DET
cblr-2960	440	46	tax	tax	NOUN
cblr-2960	440	47	planning	planning	NOUN
cblr-2960	440	48	mechanism	mechanism	NOUN
cblr-2960	440	49	.	.	PUNCT
cblr-2960	441	1	having	have	VERB
cblr-2960	441	2	to	to	PART
cblr-2960	441	3	abide	abide	VERB
cblr-2960	441	4	by	by	ADP
cblr-2960	441	5	the	the	DET
cblr-2960	441	6	tax	tax	NOUN
cblr-2960	441	7	reforms	reform	NOUN
cblr-2960	441	8	has	have	AUX
cblr-2960	441	9	caused	cause	VERB
cblr-2960	441	10	efficient	efficient	ADJ
cblr-2960	441	11	constraints	constraint	NOUN
cblr-2960	441	12	on	on	ADP
cblr-2960	441	13	tax	tax	NOUN
cblr-2960	441	14	planning	planning	NOUN
cblr-2960	441	15	.	.	PUNCT
cblr-2960	442	1	the	the	DET
cblr-2960	442	2	tax	tax	NOUN
cblr-2960	442	3	reforms	reform	NOUN
cblr-2960	442	4	have	have	AUX
cblr-2960	442	5	also	also	ADV
cblr-2960	442	6	reduced	reduce	VERB
cblr-2960	442	7	the	the	DET
cblr-2960	442	8	taxpayer	taxpayer	NOUN
cblr-2960	442	9	's	's	PART
cblr-2960	442	10	elasticity	elasticity	NOUN
cblr-2960	442	11	of	of	ADP
cblr-2960	442	12	taxable	taxable	ADJ
cblr-2960	442	13	income	income	NOUN
cblr-2960	442	14	,	,	PUNCT
cblr-2960	442	15	forcing	force	VERB
cblr-2960	442	16	the	the	DET
cblr-2960	442	17	taxpayer	taxpayer	NOUN
cblr-2960	442	18	investor	investor	NOUN
cblr-2960	442	19	to	to	AUX
cblr-2960	442	20	either	either	CCONJ
cblr-2960	442	21	refrain	refrain	VERB
cblr-2960	442	22	from	from	ADP
cblr-2960	442	23	the	the	DET
cblr-2960	442	24	use	use	NOUN
cblr-2960	442	25	of	of	ADP
cblr-2960	442	26	insurance	insurance	NOUN
cblr-2960	442	27	wrappers	wrapper	NOUN
cblr-2960	442	28	or	or	CCONJ
cblr-2960	442	29	become	become	VERB
cblr-2960	442	30	subject	subject	ADJ
cblr-2960	442	31	to	to	ADP
cblr-2960	442	32	strict	strict	ADJ
cblr-2960	442	33	control	control	NOUN
cblr-2960	442	34	requirements	requirement	NOUN
cblr-2960	442	35	and	and	CCONJ
cblr-2960	442	36	substantial	substantial	ADJ
cblr-2960	442	37	compliance	compliance	NOUN
cblr-2960	442	38	costs	cost	NOUN
cblr-2960	442	39	:	:	PUNCT
cblr-2960	442	40	effectively	effectively	ADV
cblr-2960	442	41	,	,	PUNCT
cblr-2960	442	42	the	the	DET
cblr-2960	442	43	taxpayer	taxpayer	NOUN
cblr-2960	442	44	must	must	AUX
cblr-2960	442	45	choose	choose	VERB
cblr-2960	442	46	between	between	ADP
cblr-2960	442	47	obtaining	obtain	VERB
cblr-2960	442	48	the	the	DET
cblr-2960	442	49	tax	tax	NOUN
cblr-2960	442	50	benefit	benefit	NOUN
cblr-2960	442	51	and	and	CCONJ
cblr-2960	442	52	exiting	exit	VERB
cblr-2960	442	53	the	the	DET
cblr-2960	442	54	life	life	NOUN
cblr-2960	442	55	insurance	insurance	NOUN
cblr-2960	442	56	industry	industry	NOUN
cblr-2960	442	57	altogether	altogether	ADV
cblr-2960	442	58	for	for	ADP
cblr-2960	442	59	hedge	hedge	NOUN
cblr-2960	442	60	fund	fund	NOUN
cblr-2960	442	61	investments	investment	NOUN
cblr-2960	442	62	.	.	PUNCT
cblr-2960	443	1	lastly	lastly	ADV
cblr-2960	443	2	,	,	PUNCT
cblr-2960	443	3	low	low	ADJ
cblr-2960	443	4	market	market	NOUN
cblr-2960	443	5	penetration	penetration	NOUN
cblr-2960	443	6	shows	show	VERB
cblr-2960	443	7	that	that	SCONJ
cblr-2960	443	8	the	the	DET
cblr-2960	443	9	number	number	NOUN
cblr-2960	443	10	of	of	ADP
cblr-2960	443	11	taxpayers	taxpayer	NOUN
cblr-2960	443	12	who	who	PRON
cblr-2960	443	13	incur	incur	VERB
cblr-2960	443	14	the	the	DET
cblr-2960	443	15	higher	high	ADJ
cblr-2960	443	16	costs	cost	NOUN
cblr-2960	443	17	of	of	ADP
cblr-2960	443	18	the	the	DET
cblr-2960	443	19	transaction	transaction	NOUN
cblr-2960	443	20	is	be	AUX
cblr-2960	443	21	very	very	ADV
cblr-2960	443	22	small	small	ADJ
cblr-2960	443	23	.	.	PUNCT
cblr-2960	444	1	thus	thus	ADV
cblr-2960	444	2	,	,	PUNCT
cblr-2960	444	3	the	the	DET
cblr-2960	444	4	tax	tax	NOUN
cblr-2960	444	5	reforms	reform	NOUN
cblr-2960	444	6	have	have	AUX
cblr-2960	444	7	efficiently	efficiently	ADV
cblr-2960	444	8	balanced	balance	VERB
cblr-2960	444	9	reducing	reduce	VERB
cblr-2960	444	10	the	the	DET
cblr-2960	444	11	elasticity	elasticity	NOUN
cblr-2960	444	12	of	of	ADP
cblr-2960	444	13	taxable	taxable	ADJ
cblr-2960	444	14	income	income	NOUN
cblr-2960	444	15	and	and	CCONJ
cblr-2960	444	16	the	the	DET
cblr-2960	444	17	distortionary	distortionary	ADJ
cblr-2960	444	18	effect	effect	NOUN
cblr-2960	444	19	.	.	PUNCT
cblr-2960	445	1	no	no	INTJ
cblr-2960	445	2	.	.	PUNCT
cblr-2960	446	1	2:694	2:694	NUM
cblr-2960	446	2	)	)	PUNCT