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who filed joint Federal income tax returns for 1990 and
1991. At the time they filed their petition in this case
petitioners resided in Del Rio, Texas. All references to
petitioner are to Mr. Ramon A. Garcia.
Petitioner is a physician who engages in the practice
of medicine with approximately five employees in Del Rio,
Texas. In 1976, petitioner established The Ramon A.
Garcia, M.D., P.A., Profit Sharing Plan & Trust Agreement
(the plan) in connection with his medical practice. The
plan was at all relevant times a qualified employer plan
within the meaning of section 72(p)(4). Petitioner was a
participant in the plan at all times since its inception.
He also served as plan administrator and as one of three
trustees of the trust that formed part of the plan.
Petitioner received 13 separate loans from the plan
between February 1986 and June 1992. The dates and amounts
of these loans are as follows:
Date Amount
2/03/86 $15,000.00
5/01/86 12,000.00
8/15/86 11,760.00
1/15/87 10,000.00
2/15/87 4,000.00
2/15/88 10,000.00
8/15/88 5,000.00
1/31/90 6,000.00
4/16/90 18,000.00
1/01/91 1,675.86
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