- 6 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011