Ramon A. Garcia and Bertha E. Garcia - Page 6

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                      Loan          Balance as ofBalance as of1990 AccruedTotal               
               Date Principal1990 Loans12/31/89  12/31/90 Interest Distribution          
              8/15/885,000.00        5,657.04  244.31    587.27                        
              1/31/906,000.00$6,000.00         6,461.34  461.34                        
              4/16/9018,000.0018,000.00         18,911.25 911.25                        
              1/01/911,675.86                                                          
              5/22/912,151.47                                                          
              3/24/922,500.00                                                          
              6/17/92   5,000.00 _________ _________                                  
                            24,000.00                   5,100.82 $29,100.82           

                  Respondent computed the amount of the revised                       
             deficiency for 1991 by treating the principal amount                     
             of each of the loans that petitioner received in 1991                    
             as a distribution of plan assets in 1991 (viz $3,827, as                 
             shown in the following schedule).  In addition, respondent               
             treated the aggregate unpaid interest that accrued during                
             1991 on all of the loans, except the 1986 loans, as a                    
             distribution during 1991 (viz $6,986.75, as shown in the                 
             following schedule).  As with 1990, this amount includes                 
             interest that accrued during 1991 on the loans made in                   
             1987, 1988, and 1990 that the parties agree are deemed                   
             distributions prior to 1991.  Finally, respondent treated                
             the principal amounts of the three loans that petitioner                 
             received during 1986, together with accrued interest as of               
             December 31, 1991, as a distribution in 1991 (viz                        
             $55,941.57, as shown in the following schedule).                         












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