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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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