- 33 -
5/26/89 678,125
11/24/89 678,125
5/25/90 678,125
11/26/90 678,125
5/24/91 678,125
11/26/91 678,125
5/27/92 678,125
11/25/92 678,125
5/27/93 678,125
11/26/93 18,178,125
Similarly, the schedule of payments for and receipts pursuant to
the Ironwood GIC has been stipulated by the parties as follows:
Date Payment Receipt
2/20/86 $11,047,408.05
5/27/86 $465,000
11/26/86 465,000
5/27/87 465,000
11/25/87 465,000
5/27/88 465,000
11/25/88 465,000
5/26/89 465,000
11/24/89 465,000
5/25/90 465,000
11/26/90 465,000
5/24/91 465,000
11/26/91 465,000
5/27/92 465,000
11/25/92 465,000
5/27/93 465,000
11/26/93 12,465,000
Utilizing the procedures outlined in sections 1.148-2 and
1.148-8, Income Tax Regs.,16 respondent has undertaken to show
how much the amount earned on the GIC's exceeded the amount which
would have been earned if the GIC's had been invested at a rate
16Sec. 148(i) provides that "The Secretary shall prescribe
such regulations as may be necessary or appropriate to carry out
the purposes of this section."
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