Michael Morrissey - Page 4

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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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