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Respondent calculated the aggregate deemed distribution
for 1991, $66,755.32, as follows:
Loan Balance as ofBalance as of1991 AccruedBalance as ofTotal
Date Principal1991 Loans12/31/90 12/31/91 Interest 12/31/91 Distribution
2/03/86$15,000.00 $26,469.16
5/01/8612,000.00 9,720.53
8/15/8611,760.00 19,751.88
1/15/8710,000.00 $14,482.98$15,986.50$1,503.52
2/15/874,000.00 5,793.19 6,394.60 601.41
2/15/8810,000.00 13,120.8714,482.98 1,362.11
8/15/885,000.00 6,244.31 6,892.56 648.25
1/31/906,000.00 6,461.34 7,132.11 670.77
4/16/9018,000.00 18,911.2520,874.18 1,962.93
1/01/911,675.86$1,676.00 1,804.87 128.87
5/22/912,151.47 2,151.00 2,259.89 108.89
3/24/922,500.00
6/17/92 5,000.00 __________ _________ __________
3,827.00 6,986.7555,941.57$66,755.32
1The difference between the principal amounts of the loans
petitioner received in 1991 and the amounts respondent includes in the
deemed distribution for the year is presumably attributable to
rounding.
We note that in calculating the unpaid balance of the
1986 loans as of December 31, 1991, respondent applied the
$8,545 payment that petitioner made on April 11, 1989, to
the outstanding balance of the May 1, 1986, loan as of the
date of the payment. We also note that, in computing the
revised deficiency, respondent did not treat the principal
amounts of the loans petitioner received in 1987, 1988, or
1992 as taxable distributions in either of the years at
issue.
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