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The terms of the 1982 note evidencing the 1982 plan loan provide
no specific repayment date for the $130,000 of principal and
require interest to be paid annually at the rate of 15 percent
per year. Accordingly, the 1982 plan loan is not a loan de-
scribed in section 72(p)(2). On the instant record, we reject
respondent's argument that section 72(p)(3) disallows the inter-
est deductions at issue relating to the 1991 interest payment on
the 1982 plan loan.
Based on our examination of the entire record presented to
us, we reject respondent's determinations and find that petition-
ers are entitled for the years at issue to interest deductions
under section 163(a), as limited by section 163(d), that are
attributable to the 1991 interest payment on the 1982 plan loan.
Section 6662(a)
Section 6662(a) imposes an addition to tax equal to 20
percent of the underpayment of tax attributable to, inter alia,
negligence or disregard of rules or regulations under section
6662(b)(1).8 For purposes of section 6662(a), the term "negli
8 Respondent made alternative determinations in the notice that,
assuming arguendo that the Court were not to find petitioners
liable for the years at issue under sec. 6662(a) because of their
negligence or disregard of rules or regulations under sec.
6662(b)(1), they are liable under sec. 6662(a) for those years
because of substantial understatements of income tax under sec.
6662(b)(2). On brief, respondent does not advance any arguments
in support of the alternative determinations under sec. 6662(a)
that were based on sec. 6662(b)(2). We conclude that respondent
has abandoned the determinations under sec. 6662(a) that were
(continued...)
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