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The DBP ceased benefit accruals in 1990. When it did, the
DBP had three participants, including petitioner, all of whom
were 100 percent vested. Each of these participants, except for
petitioner, was paid his or her benefits at that time. The DBP
was formally terminated as of September 26, 1990.
The MPP was operational throughout its taxable year that
ended on October 31, 1990. The MPP had two participants at the
beginning and end of that year. Petitioner was one of these
participants. The record does not identify the other
participant.
From November 14, 1979, to February 17, 1989, the Plans made
23 loans to petitioner. Each of these loans, but one, was
evidenced by a "promissory note" or an "installment note" signed
by petitioner as the obligor.1 As stated on the notes, the dates
of the loans, the obligees, the original loan amounts, and the
interest rates for these loans, some of which were unsecured and
others of which were secured by petitioner's accounts in the
Plans, were as follows:
1 The record does not contain the signature page of one of
the 22 notes. Given the fact that petitioner signed each of the
other 21 notes, we find that he also signed the 22d note.
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