A participant bought a life insurance policy from a plan several years ago. During the time the policy was in the plan, he paid income tax against the "PS 58 cost" portion of the premium each year. Several years later he cashed out the policy, and there is now gain (relative to the original exchange price) that will now be taxed. For purposes of determing the gain, is the participant's cost basis the exchange price, or is it the exchange price plus the sum of the PS 58 costs?