You own individual retirement account and non-IRA assets. You want a certain amount of your estate to pass to charity, and you want the charitable gift to be as tax efficient as possible to maximize the balance that will pass to your children (or other young heirs). You may have heard that your IRA is the “perfect match” for charitable giving because the pre-income tax dollars in the IRA can pass to charity with little or no income tax cost. You may also have heard that your IRA could be quite valuable if left to your younger heirs with “stretched-out” distribution planning under the minimum required distribution (MRD) rules. And lately, you've probably heard that Roth IRA conversions are all the rage. Which approach is the best fit for you? The answer might surprise you.

We developed the following case study to explore these questions. It compares several alternative strategies relating to charitable giving and evaluates the “success” of each strategy. The case study measures “success” by modeling investment performance, cash flow, income tax, estate tax and many other variables for each strategy over a 55-year time period and then calculating the pile of money that has accumulated for the children at the end of the period, net of all taxes and expenses.1 Thus, the strategy that produces the biggest pile of “after tax” money for the children at the end of the deferral period wins!

Financial Case Study

Our case study assumes these facts:

Our client, whom we'll call “Wellington,” is 65 years old and owns the following assets: a $2 million IRA; liquid investments worth $10 million; and a residence worth $1 million.

It's early in the year 2010, and Wellington wants to make a provision of $2 million for her favorite public charity. The gift can be made now, over time or at death, but any portion of the $2 million that isn't given now must include the investment earnings that accrue in the interim. In other words, $2 million of current principal plus any earnings thereon will be committed to charitable giving.

In addition, she wants to make the charitable gift in the most tax-efficient manner to maximize what is left for her child, age 30. She asks whether she should fund the charitable gift with IRA assets or non-IRA assets, whether she should make the charitable gifts during life or at death and whether she should consider a Roth IRA conversion.

We assume the following:

  • The investment portfolio for Wellington and her child (IRA and non-IRA) produces 6 percent net annual return, consisting of 1.5 percent income (further broken down as 0.9 percent dividend income and 0.6 percent taxable interest), 5.5 percent growth and 1 percent investment costs. Excess cash flow is invested in the investment portfolio (both by Wellington and her child). Investment fees relating to IRA accounts are paid from inside the account. Investment fees relating to Roth IRA accounts are paid from non-Roth IRA assets.2 Portfolio turnover is 20 percent per year.
  • Wellington receives a $150,000 pension each year (in addition to the IRA), $15,000 of social security (indexed for inflation) and has living expenses of $200,000 per year (indexed for inflation).
  • Annual inflation will be 1.5 percent throughout the projection period.
  • Wellington has not made any prior taxable gifts.
  • The projections assume that Wellington will die at age 84 (Dec. 31, 2029). Given the child's age (age 49 in the year of Wellington's death), any MRDs from IRA or Roth IRA accounts designated to the child will continue through the year 2064. Thus, this case study evaluates a 55-year deferral period, starting in 2010 and continuing through 2064. During Wellington's lifetime, MRDs from Wellington's IRA are based on the Uniform Lifetime Table factors (years 2015 through 2029). After her death, distributions continue for her child through the year 2064 based on factors derived from the child's single life expectancy as measured the year following death.
  • Wellington's child earns $40,000 per year (indexed) and has living expenses of $30,000 per year (indexed). When the child reaches age 65, she will receive social security benefits of $8,000 per year (in 2010 dollars, indexed for inflation).
  • Federal income tax laws are assumed to reflect what would happen if the provisions of the Economic Growth and Tax Relief Reconciliation Act sunset as scheduled. State income tax is assumed to be 9.5 percent of federal adjusted gross income and to generally conform to federal rules (for example, the timing of Roth IRA conversion income recognition). The financial model is quite detailed in applying income tax laws. For example, the model includes provisions for the 3.8 percent surtax on net investment income that takes effect in 2013, alternative minimum tax, taxation of a portion of social security, the 3 percent phase-out (“haircut”) of itemized deductions, limitations on charitable deductions, compressed rate brackets for trusts, income with respect to a decedent (IRD) deduction, etc. (The IRD deduction is utilized on the earliest dollars distributed.)
  • Federal estate tax laws and stepped-up cost basis rules are assumed as if the rules in effect in 2009 were made permanent. It's assumed that no state death tax applies.

Charitable Gift Strategies

Let's start off with our first strategy, the base case, (withdrawal and donation of IRA assets in 2010), which is the strategy against which we'll measure the other eight strategies.

Strategy 1: Distribute IRA and donate in 2010 (the base case)

Wellington withdraws the entire $2 million from her IRA in 2010, deposits the funds in her own account and then writes a check to a public charity for the same amount. She reports $2 million of gross income on the IRA distribution, and is entitled to a charitable deduction in connection with her charitable gift, subject to the limitations described below.

Strategy 2: Direct IRA charitable rollover in 2010

Proponents have been fighting for years for a permanent law change that allows lifetime charitable gifts to be made directly from IRAs to charities. A temporary law was in effect through 2009 that severely limited the gift amount and was available only to those who have attained age 70 ½. (See “Direct Rollovers to Charity,” p. 42.)

Obviously, Wellington doesn't qualify to make a direct charitable rollover because her transaction occurred in 2010, is way over the $100,000 limit and she hasn't attained age 70 ½. Nevertheless, this strategy is included as if allowed under the law to help evaluate the degree of advantage a charitable rollover can provide to others who might qualify under current or future law. Thus, under this strategy, Wellington directs her IRA custodian to transfer the $2 million directly to the charity in 2010. No income is recognized and no deduction is claimed.

Strategy 3: Lifetime MRDs; IRA to charity at death

Wellington gives her entire IRA to charity, but not all at once. Instead, she takes MRDs from her IRA during her lifetime and makes corresponding gifts to charity each year. She designates the remaining balance of her IRA to pass to charity at her death. At Wellington's death, the balance of the IRA passes to charity and no income tax is payable by Wellington's estate or heirs.

Strategy 4: Lifetime MRDs; IRA to child at death

Wellington takes MRDs during life and makes corresponding gifts to charity each year. But at death, she uses non-IRA assets to satisfy the balance of the charitable gift intended, and her child is designated as the IRA death beneficiary. This qualifies the child to take “stretched-out” MRDs over the child's lifetime. This case study assumes that the child will take full advantage of this plan. The post-death IRA distributions are taxable income to the child. (The child is allowed a partial offset in the form of the IRD deduction.)

Strategy 5: Larger gifts to charity during life; IRA to child at death

Wellington takes MRDs during her life and increases her lifetime donations to complete the charitable gift while alive, to ensure that an income tax benefit is obtained for all charitable gifts. As in the prior strategy, at death she designates her child as the IRA death beneficiary in a way that qualifies the child to take “stretched-out” MRDs over the child's lifetime.

Strategy 6: Same as Strategy 5, except appreciated securities

Wellington follows the same approach as in Strategy 5, except that she makes the lifetime gifts to charity using appreciated marketable securities instead of cash. The financial model assumes that she selects securities with cost basis equal to 40 percent of fair market value at the time of each gift.

Strategy 7: Roth IRA conversion; pay tax in 2011 and 2012

Wellington converts her IRA to a Roth IRA in 2010, and takes advantage of the default two-year deferral rule, thus recognizing half of the income from the conversion in 2011 and the other half in 2012.3 She will not be required to take any MRDs from her Roth IRA while living.4 She designates her child as the Roth IRA death beneficiary in a way that qualifies the child to take “stretched-out” MRDs over the child's lifetime. Wellington makes her entire charitable gift in 2011 using non-Roth IRA cash. To raise this cash, she liquidates securities in her portfolio late in 2010. The financial model assumes that she selects securities with cost basis equal to 80 percent of fair market value at the time of liquidation.

Strategy 8: Roth IRA conversion; pay tax in 2010

Wellington converts her IRA to a Roth IRA in 2010, elects to report all of the conversion income in 2010, and makes the entire charitable gift in 2010 using non-Roth IRA cash. To raise this cash, she must liquidate securities in her portfolio. The financial model assumes that she selects securities with cost basis equal to 80 percent of fair market value at the time of liquidation.

Strategy 9: Same as Strategy 7, except appreciated securities used

Wellington follows the same Roth IRA conversion strategy as in Strategy 7, except that she structures the charitable gift to include non-IRA marketable securities instead of cash, to the extent that doing so provides a tax benefit after taking into account the different charitable deduction limitations that apply. The financial model assumes that she selects securities with cost basis equal to 40 percent of fair market value at the time of the gift.

Case Study Results

Our case study results show us what's left for the child at the end of the deferral period. The fact patterns were carefully designed to ensure that charity ends up with exactly the same amount of gifts at the end of the deferral period under every strategy. This allows us to leave the charity's assets out of the results and narrow our focus to the assets remaining for the child at the end of the deferral period as our measurement of the success of each strategy.

The best way to understand the results is to begin with the bar graph. (See “What's Left for the Child?”this page.) Each bar shows the total amount of assets, net of all taxes and expenses, remaining for the child at the end of the deferral period. However, part of each bar would be there whether there is an IRA or not (the baseline amount). This baseline amount has been calculated and is shown as the dark green section of each bar. This amount is constant across each of the strategies.

The lighter green portion of each bar shows the additional assets, net of all taxes and expenses, remaining at the end of the deferral period as a result of the IRA strategy being illustrated.

“Percentage Increase in Additional After Tax Assets,” p. 45, shows the additional after tax assets in numerical terms. The chart shows the additional amount (in 2010 dollars) that each IRA distribution strategy produces. For example, the assets remaining for the child at the end of the deferral period in Strategy 1 are $4,049,584 higher than the baseline amount. We can also compare these additional amounts in percentage terms, with Strategy 1 being used as the basis of comparison to the other strategies.

So, what are these results telling us about each strategy?

Strategy 1: Distribute IRA and donate in 2010 (the base case)

Under this strategy, Wellington recognizes $2 million of income and makes a $2 million donation, but the donation is subject to the 50 percent of adjusted gross income (AGI) limitation on charitable deductions,5 which creates a “mismatch.” Wellington is limited to a deduction in 2010 of roughly $1.320 million and must carry the excess forward. To the extent she's unable to use the excess in the following five years, she permanently loses the deduction. As it turns out in this case, the excess deduction amount is fully utilized over the following two years.

Wellington wasn't impacted by the overall limitation on itemized deductions provided under Internal Revenue Code Section 68, because this provision isn't in effect for 2010 (but this provision returns in 2011 under current law). Had this provision been in effect in 2010, Wellington would have been subject to disallowance of roughly $75,000 of deductions. The limitation is tied to AGI, so the extra income from the IRA distribution increases the severity of this provision.

Strategy 1 isn't the highest performing strategy, but it's useful as the base case that will be the basis of comparison for the other strategies.

Strategy 2: Direct IRA charitable rollover in 2010

The results for Strategy 2 illustrate that the potential benefit of the direct rollover, if allowed by law, is quite modest — roughly 1 percent in this case compared to Strategy 1. It may be surprising to some that the direct charitable rollover doesn't provide a more substantial benefit for a high income taxpayer.

Strategy 3: Lifetime MRDs; IRA to charity at death

Strategy 3 avoids the mismatch caused by the 50 per cent of AGI limitation by spreading lifetime charitable gifts over multiple years. But mismatches still occur because the income from the MRDs increases AGI and adversely impacts the overall limitation on itemized deductions in years after 2010. As a result, Strategy 3 produces an outcome that's somewhere in between the outcomes of Strategies 1 and 2.

Strategy 4: Lifetime MRDs; IRA to child at death

Strategy 4 was designed to test the conventional wisdom that it's generally best to designate IRAs to charity when a charitable gift is intended at death. The lifetime donations in Strategy 4 are handled in the same manner as in Strategy 3, but the final gift to charity at death is made with non-IRA assets.

Some may be surprised to see that the “IRA to child” approach of Strategy 4 produces a 6 percent improvement over the “IRA to charity” approach of Strategy 3. However, the results for other fact patterns can vary substantially.

For example, if net investment yield is 1 percent higher, Strategy 4 produces a 12 percent improvement over Strategy 3. If net investment yield drops below roughly 4.75 percent, Strategy 3 begins to outperform Strategy 4.

If the child is 10 years older, Strategy 3 outperforms Strategy 4 by roughly 6 percent (due to the shorter deferral period). If the child is 10 years younger, Strategy 4 outperforms Strategy 3 by 20 percent.

Thus, the decision whether to make a gift to charity at death with IRA or non-IRA assets should be made on a case-by-case basis-there's no general rule for all situations.

Strategy 5: Larger gifts to charity during life; IRA to child at death

Strategy 4 provides the best benefit so far, but leaves some chips on the table because there's no income tax benefit derived from the gift to charity at death funded with non-IRA assets. Strategy 5 is designed to address this by increasing the yearly cash donations to ensure that an income tax benefit is obtained for every dollar donated. Strategy 5 substantially outperforms all prior strategies (39 percent more than Strategies 1 and 3).

Thus, for the client who is willing to make all charitable gifts while living, stretch-out planning with the IRA is a clear winner.

Strategy 6: Even better — use appreciated securities

We can further improve on the benefit of Strategy 5 if Wellington uses appreciated securities to fund the lifetime charitable gifts instead of cash. This strategy produces a 54 percent improvement over Strategy 1 and a 15 percent improvement over Strategy 5. The reason for the increase is that a charitable deduction may be claimed based on the fair market value of the securities contributed, which avoids any capital gain on appreciation in the securities.6 Note that the charitable deduction limitation is 30 percent of AGI, instead of 50 percent, for appreciated capital assets that are deducted at fair market value.7 In Strategy 6, this limitation isn't a problem because the gifts occur gradually over a number of years.

Strategy 7: Roth IRA conversion; pay tax in 2011 and 2012

In Strategy 7, Wellington converts her IRA to a Roth IRA in 2010 and pays income tax on the conversion half in 2011 and half in 2012. She makes the full charitable gift in 2011. The large charitable deduction helps offset the ordinary income from the Roth IRA conversion, but due to the 50 percent of AGI limitation, it still takes four years to fully use the charitable deduction. Nevertheless, Strategy 7 produces a 328 percent outcome compared to Strategy 1 — a terrific result.

One of the reasons the Roth IRA performs so well is that it significantly reduces exposure to the new 3.8 percent Medicare contribution tax that takes effect in 2013.8 This additional tax doesn't apply to retirement plan distributions, but the tax on other investment income may be higher if AGI is increased by taxable IRA distributions. The Roth IRA avoids this problem. In addition, a greater portion of the true spending power of Wellington's overall portfolio is concentrated in the favorable Roth IRA vehicle. This means not only that her AGI is lower, but also that the investment earnings that are subject to the surtax are lower, too.

The impact of this new 3.8 percent tax is surprisingly high. The total assets accumulated at the end of the deferral period are roughly 9 percent lower under Strategies 1, 2 and 3. In 2010 dollars, this represents roughly $2 million less. The IRA stretch-out for the child under Strategies 4, 5 and 6 helps reduce this impact, and the total assets lost range from 7 to 8 percent. The Roth IRA conversion strategies are least impacted, with total assets lost of about 4 percent.

Note that investment advisory expenses are paid from outside the Roth IRA account throughout the deferral period to maximize the benefit of the Roth IRA. Had these expenses been paid inside the Roth IRA, the outcome would have been 277 percent instead of 328 percent.

Strategy 8: Roth IRA conversion; pay tax in 2010

In Strategy 8, Wellington converts her IRA to a Roth IRA in 2010 and opts to pay income tax on the conversion in 2010. She also makes the full charitable gift in 2010. The outcome is approximately the same as the outcome of Strategy 7 in this case, but may not be the same in other fact patterns.

Strategy 9: Same as Strategy 7, except appreciated securities used

Strategy 9 is the same as Strategy 7 except that Wellington uses appreciated securities to fund the lifetime charitable gift in 2011. The strategy gets more complicated in this strategy, because of the 30 percent of AGI limitation.

If the entire charitable gift is made in 2011 with appreciated marketable securities, Strategy 9 produces a worse outcome than Strategy 7. This is because the deduction is gradually claimed over a seven-year period due to the lower limitation. In fact, a significant portion of the deduction is permanently lost because it can't be claimed within the five-year carry forward period. This occurs even if part of the charitable gift is staggered into 2012.9

It turns out that the optimal result is accomplished if roughly half of the charitable gift is funded with appreciated marketable securities and the balance is funded with cash. This blend will vary from case to case. In this case, it produces an overall outcome of 334 percent, a 6 percent increase over Strategies 7 and 8.

Consider All Factors

For a client like Wellington, who has both charitable and non-charitable objectives, this case study highlights that there are a number of factors to be considered before concluding that designating an IRA to charity is the best approach. In fact, in many situations, it clearly will not be the best approach.

If the charitable gifts can be made during lifetime, and if there are younger heirs who will take advantage of stretched-out distributions, it's likely that stretch-out planning — particularly a Roth IRA conversion — will provide the best overall results.

Endnotes

  1. The case study was carefully designed to ensure that charity ends up with exactly the same amount of gifts at the end of the day under each strategy, which is essential to ensure an “apple- to-apples” comparison.
  2. The issue of whether it's better to pay fees from inside or outside a retirement account is addressed in Steven E. Trytten, “Estate Planning for Retirement Plans of the Rich and Famous,” 42nd Annual Heckerling Institute on Estate Planning Institute (2008). Financial modeling suggests that (1) it's always better to pay fees from outside of a Roth IRA account, and (2) as a general rule, it's better to pay fees from inside an IRA or traditional retirement account, but sometimes it's better to pay from outside early in the deferral period.
  3. Internal Revenue Code Section 408A(d(3)(a)(iii).
  4. IRC Section 408A(c)(5).
  5. IRC Section 170(b)(1)(A).
  6. IRC Section 170(e)(5).
  7. IRC Section 170(b)(1)(C).
  8. IRC Section 1411, added by the 2010 Health Care Act Section 1402(a)(1). For a more detailed presentation of other reasons why a Roth IRA performs well, see Steven E. Trytten, “Show Me the Money,” Trusts & Estates, September 2009 at p. 34.
  9. IRC Section 170(b)(1)(B).

Steven E. Trytten is a partner in the Pasadena, Calif. office of Anglin, Flewelling, Rasmussen, Campbell & Trytten LLP

Direct Rollovers to Charity

The Pension Protection Act of 2006 permitted such a strategy for a limited time

The Pension Protection Act of 2006 permitted such a strategy for a limited time The Pension Protection Act of 2006 (PPA)1 added Internal Revenue Code Section 408(d)(8), allowing so-called “direct charitable rollovers” from individual retirement accounts for a limited time, which was extended through 2009.2 There were several unsuccessful attempts to enact such a provision in previous years. Proponents argue that such a provision is needed so those who wish to make lifetime contributions of IRA funds can do so without being penalized by the cutbacks and limitations that otherwise apply to itemized deductions for charitable contributions. Here are the specifics of the PPA provision that was ultimately enacted:

  • A distribution from an IRA owned by an individual after attaining age 70 ½ made directly by the IRA trustee or custodian to certain charitable organizations (described below) during the years 2006 through 2009 (a qualified charitable distribution or QCD), may qualify for special tax treatment as follows.
  • QCDs made in any taxable year that, in the aggregate, don't exceed $100,000 are excluded from gross income.3
  • The plan owner doesn't claim a charitable deduction,4 and QCDs aren't taken into account in determining limitations that might apply to the plan owner's other charitable deductions under IRC Section 170, which imposes deduction limitations based on a percentage of adjusted gross income (AGI).5 However, the QCD must satisfy the substantiation requirements that would otherwise apply to support a charitable deduction under Section 170.6
  • For calendar year taxpayers, the provision is generally limited to distributions occurring during calendar years 2006 through 2009, since the new provision (1) is effective for distributions occurring in taxable years beginning after Dec. 31, 2005,7 and (2) doesn't apply to distributions occurring in taxable years beginning after Dec. 31, 2009.8
  • Distributions must be from an individual retirement plan (that is, an IRA or individual retirement annuity), other than a simplified employee pension (SEP) 9 or a simple retirement account,10 to qualify as QCDs.11
  • A distribution must occur on or after the date on which the “person for whom the plan is maintained” attains age 70 ½.12 Notice 2007-713 clarifies that the exclusion is available for QCDs from “any type of IRA” except ongoing SEP IRAs and SIMPLE IRAs, including “inherited” IRAs. In the case of an “inherited” IRA, the individual for whom the inherited IRA is maintained must have attained age 70 ½.14
  • To qualify as QCDs, distributions must be made directly by the plan trustee to so-called “public” charities”15 (other than so-called “supporting organizations”16 or “donor advised funds”17),18 and must otherwise be fully deductible.19 Notice 2007-7 clarifies that a check from an IRA payable to a charitable organization satisfies the direct payment requirement, even if delivered by the IRA owner. As a practical matter, many IRA owners will want to deliver the check to ensure the charitable recipient knows where the gift came from, and to coordinate substantiation paperwork.
  • The new provision clarifies that a distribution qualifies as a QCD only if the distribution would otherwise be includible in gross income.20 Since the general rules governing taxation of distributions require aggregating all IRAs and all distributions as if from one contract,21 the owner of a plan that includes non-taxable contributions could potentially have a non-taxable component to his overall distributions in any year. The new provision addresses this issue by including a special rule that provides (1) for purposes of determining whether a distribution qualifies as a QCD, the entire distribution is treated as otherwise includible in gross income if it doesn't exceed the aggregate amount of gross income that would be determined by applying the general rule of aggregation to all distributions; and (2) for purposes of determining the taxability of other distributions in the current and subsequent years, “proper adjustments shall be made” to recognize the QCD distributions as having come entirely from taxable amounts, thus allocating non-taxable amounts to non-QCD distributions.22
  • QCDs count towards satisfying minimum distribution requirements.23
  • A “direct charitable rollover” allowed under the Internal Revenue Code may or may not be recognized under the income tax laws of all states, but would be recognized in this author's state of California.24

Endnotes

  1. The Pension Protection Act of 2006, P.L. 109-280, Aug. 17, 2006.
  2. 2008 Extenders Act Section 205(a).
  3. Internal Revenue Code Section 408(d)(8)(A).
  4. IRC Section 408(d)(8)(E).
  5. Para. 5175, Joint Committee on Taxation Report [JCX-38-06].
  6. Notice 2007-7, 2007-5 IRB 395, Q&A-39.
  7. Pension Protection Act of 2006, Section 1201(c)(1), P.L. 109-280, Aug. 17, 2006.
  8. IRC Section 408(d)(8)(F) as extended by 2008 Extenders Act Section 205(a).
  9. As defined in IRC Section 408(k).
  10. As defined in IRC Section 408(p).
  11. IRC Section 408(d)(8)(B) (flush language).
  12. IRC Section 408(d)(8)(B)(ii).
  13. 2007-5 IRB 395, Q&A 36-37.
  14. Ibid., Q&A 37.
  15. As defined in IRC Section 170(b)(1)(A).
  16. As defined in IRC Section 509(a)(3).
  17. As defined in IRC Section 4966(d)(2).
  18. IRC Section 408(d)(9)(B)(i).
  19. That is, fully allowable under IRC Section 170, disregarding subsection (b) thereof. See IRC Section 408(d)(8)(C).
  20. IRC Section 408(d)(8)(B) (flush language).
  21. IRC Section 408(d)(2).
  22. IRC Section 408(d)(8)(D); see also supra note 5.
  23. See supra note 5.
  24. California Rev. & Tax. Code Section 17501(b).
    — Steven E. Trytten

What's Left for the Child?

The additional after tax assets remaining after the deferral period are greatest using Strategy 9

Each bar represents the child's total after tax assets for each individual retirement account scenario at the end of the deferral period (when the IRA is fully distributed). After tax assets include assets from all sources inside and outside the IRA, net of all taxes.

  • Baseline after tax assets is the portion of after tax assets at the end of the deferral period that would occur even if there is no IRA

  • Additional after tax assets is the balance of after tax assets at the end of the deferral period in excess of baseline after tax assets. This amount reflects the added value from IRA distributions over the deferral period
    Steven E. Trytten

Percentage Increase in Additional After Tax Assets

The outcomes vary, depending on the charitable strategy used

ASSUMPTIONS:
IRA beginning balance: $2 million
Deferral period begins: 2010
IRA owner dies: 2029
Through: 2064 Number of years: 55
IRA owner's age at death : 84 Child's age year after IRA owner's death: 50
IRA distribution strategy (1) Distribute IRA and donate in 2010 (base case) (2) IRA charitable rollover in 2010 (3) Lifetime MRDs; IRA to charity at death (4) Lifetime MRDs; IRA to child at death (5) Larger gifts to charity during life; IRA to child at death (6) Same as (5), except appreciated securities (7) Roth IRA conversion; pay tax in 2011/2012 (8) Roth IRA conversion; pay tax in 2010 (9) Same as (7), except appreciated securities
Child's additional after tax assets at end of deferral period for each IRA scenario (in today's dollars) $4,049,584 $4,090,475 $4,059,095 $4,280,776 $5,610,796 $6,219,699 $13,265,552 $13,294,984 $13,516,569
Percent comparison of additional after tax assets 100% 101% 100% 106% 139% 154% 328% 328% 334%

Steven E. Trytten