- 5 -
Original
Date Of loan Obligee1 loan amount Interest rate
11/14/79 MPPT $4,500 12%
05/01/81 MPPT 10,000 16
10/01/81 MPPT 10,000 16
01/04/82 MPPT 145,000 16
06/11/82 MPPT 7,000 16
08/02/82 MPPT 30,000 14
01/03/83 MPPT 60,000 11
unstated MPPT 6,000 11
02/08/84 Pension Plan 13,000 11
01/08/85 MPPT 153,687 11
08/27/85 Pension Plan 50,000 12
09/17/85 MPPT 20,000 11
12/03/85 Pension Trust 5,500 10
01/03/86 Pension 14,500 10.50
04/15/86 MPPT 5,000 9
07/30/87 MPPT 50,000 9.50
10/08/87 MPPT 25,000 10
12/09/87 MPPT 25,000 9.75
02/01/88 MPPT 15,000 unstated
02/12/88 BP Trust 20,000 9.75
12/09/88 Pension 2,000 11.50
12/09/88 MPPT 8,000 11.50
02/17/892 2,000 11.50
Total 681,187
1 Each note references the obligee as "MPPT", "DBT Trust",
"Pension Plan", "Pension Trust", or "Pension". We believe that
"MPPT" and "DBP Trust" refer to the money purchase plan trust and
the defined benefit plan trust, respectively, and we so find. We
are unable to find which of the Trusts was the obligee where the
note listed the obligee as "Pension Plan", "Pension Trust", or
"Pension".
2 The record does not contain a note for the loan that was
made on Feb. 17, 1989. The parties have stipulated the
information shown on this line.
None of the loan amounts was ever included in petitioner's
gross income as a distribution.
On October 1, 1990, petitioner's obligations to repay the
loans from the Plans totaled 100 percent of the Trusts'
assets.2 Eighteen days later, when petitioner owed the Plans
2 Most of the Trusts' assets consisted of assets held by the
(continued...)
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011