- 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