- 23 - regular course of dealing was established prior to the years before the Court. Based on the foregoing, we find that petitioners have failed to prove that the 1986 loans were renewed, renegotiated, modified, or extended after 1986 within the meaning of the 1986 Act effective date provisions. We therefore hold that the level amortization requirement contained in 1986 Act is not applicable to such loans. Cf. Hickman v. Commissioner, T.C. Memo. 1997-545. Hence, the interpretation of that provision contained in the proposed regulation, discussed above, on which petitioners rely, is not applicable to the 1986 loans. Accordingly, we sustain respondent's determination that the outstanding balance of the 1986 loans as of December 31, 1991, constitutes a distribution of plan assets to petitioners in 1991. Unpaid Interest Accrued During 1990 and 1991 Respondent treats the unpaid interest that accrued during 1990 and 1991 on all of the loans, other than the 1986 loans, as distributions of plan assets in those respective years. These amounts consist, either entirely or in substantial part, of interest that accrued after thePage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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