- 43 -
Transit made no quarterly interest payments to LIIBV from
May 1986 to November 1987. LWSI made no quarterly interest
payments to LIIBV from February to August 1988. Instead, LIIBV
increased Transit's and LWSI's account balances to include the
interest payments due during that time.
During their 1989 taxable years, Transit, LWSI, and Tree
increased their account balances to include interest on the
interest reinvestment loans from LIIBV.
b. Summary of Interest Payments and Interest
Reinvestment Loans in the Years in Issue
The following table shows interest reinvestment loans and
what petitioners contend are interest payments in the years in
issue:
Date Interest Claimed Claimed Claimed Total
Reinvestment Interest Interest Interest Claimed
Loan From Payment Payment Payment Interest
LIIBV From From LWSI From Tree Payments to
Transit to to LIIBV to LIIBV LIIBV
LIIBV
5/29/86 $988,797*+ $809,057 $179,740 - $988,797
8/28/86 2,204,674* 1,630,716 573,958 - 2,204,674
11/25/86 5,870,270* 3,097,820 2,772,450 - 5,870,270
2/25/87 11,535,627* 4,003,389 7,532,238 - 11,535,627
5/28/87 12,468,151* 4,479,972 7,988,179 - 12,468,151
8/31/87 15,280,674* 5,071,716 10,297,291 $546,667 15,915,674
11/30/87 16,700,000* 5,705,723 10,597,883 549,028 16,852,634
2/29/88 12,448,000** 6,346,87411,991,976 539,583 18,878,433
5/31/88 21,045,000** 7,534,62115,015,471 542,499 23,092,591
8/31/88 22,000,000** 8,580,48516,546,460 581,666 25,708,611
Total 120,541,193 47,260,373 83,495,646 2,759,443 133,515,462
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