- 8 - outstanding loan balance of $50,000 despite the $10,000 loan payment which Dura-Craft made to David Christie in 1985. Accordingly, as of the date of its payment, Dura-Craft owed interest to Milo Chapman and David Christie in the amount of $33,000 rather than the $37,185 which was paid. On February 22, 1986, the loan principal and interest due to the Plan for each of the plan loans exceeded the statutory limit of $50,000, pursuant to section 72(p)(2)(A)(i). Total interest of $9,000 and $3,000 accrued on the plan loans during 1988 and 1989, respectively. The Chapmans and the Christies did not report any income with respect to the corporate or plan loans. Respondent determined that the Chapmans and the Christies each received two plan distributions from the Plan pursuant to section 72(p): (1) In 1988, in the amount of the principal balance of $37,500 and one-half of the accrued interest ($4,500), and (2) in 1989, in an amount of one-half of the interest accruing during that year ($1,500). In addition, respondent determined that petitioners were liable for an additional 10-percent tax pursuant to section 72(t) on each distribution. Respondent also determined that the Chapmans and the Christies each received the following amounts of income in 1989: (1) Dividends from Springbrook equal to one-half of the difference between interest of $14,000 owed by Springbrook on its corporate loan and the $18,315 actually paid by Springbrook toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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