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regular course of dealing was established prior to the
years before the Court.
Based on the foregoing, we find that petitioners
have failed to prove that the 1986 loans were renewed,
renegotiated, modified, or extended after 1986 within
the meaning of the 1986 Act effective date provisions.
We therefore hold that the level amortization requirement
contained in 1986 Act is not applicable to such loans. Cf.
Hickman v. Commissioner, T.C. Memo. 1997-545. Hence, the
interpretation of that provision contained in the proposed
regulation, discussed above, on which petitioners rely, is
not applicable to the 1986 loans. Accordingly, we sustain
respondent's determination that the outstanding balance of
the 1986 loans as of December 31, 1991, constitutes a
distribution of plan assets to petitioners in 1991.
Unpaid Interest Accrued During 1990 and 1991
Respondent treats the unpaid interest that accrued
during 1990 and 1991 on all of the loans, other than the
1986 loans, as distributions of plan assets in those
respective years. These amounts consist, either entirely
or in substantial part, of interest that accrued after the
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