Michael Morrissey - Page 5

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                                                        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...)                 





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