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Date Amount
5/22/91 2,151.47
3/24/92 2,500.00
6/17/92 5,000.00
Each loan is evidenced by a written note, and the terms of
the notes are set forth on substantially identical forms.
Each note requires repayment over a 5-year period "in 20
quarterly installments", together with interest at the rate
of 10 percent per annum.
Petitioner did not make payments in accordance with
the terms of the notes. He made only two payments. On
April 11, 1989, he made a partial payment of $8,545, and
sometime in 1994, he paid the entire outstanding balance
of all of the loans, including all accrued interest.
There is no written agreement or other document evidencing
a renegotiation, extension, renewal, or revision of any
part of the plan or any of the loans. Petitioners did not
include any of the loans in the gross income reported on
their Federal income tax returns.
Prior to trial, respondent made concessions which
resulted in reduced deficiencies and penalties. The
amounts now in dispute are as follows:
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Last modified: May 25, 2011