Ramon A. Garcia and Bertha E. Garcia - Page 11

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                            made) as the principal residence of the                   
                            participant or a member of the family                     
                            * * *.                                                    

             This provision applied to all loans made after August 13,                
             1982.  See 1982 Act, sec. 236(c)(1), 96 Stat. 324, 510.                  
                  As part of the Tax Reform Act of 1986 (the 1986 Act),               
             Pub. L. 99-514, sec. 1134(b), 100 Stat. 2085, 2484,                      
             Congress amended section 72(p) by, inter alia, adding a                  
             new subparagraph (2)(C), which imposes an additional                     
             requirement for the exception contained in section                       
             72(p)(2).  That provision states as follows:                             

                  (C) Requirement of level amortization.--Except as                   
                  provided in regulations, this paragraph shall not                   
                  apply to any loan unless substantially level                        
                  amortization of such loan (with payments not less                   
                  frequently than quarterly) is required over the                     
                  term of the loan.                                                   

             Under this level amortization requirement, a loan is not                 
             eligible for the exception contained in section 72(p)(2)                 
             unless it requires substantially level amortization over                 
             the term of the loan, with payments no less frequently than              
             quarterly.  See id.  This level amortization requirement                 
             applies only to loans that are made, renewed, renegotiated,              











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