Gideon L. and Corazon P. Medina - Page 4

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               Gideon Medina was an employee, the sole shareholder, and               
          president of Gideon L. Medina, M.D., P.C., a Michigan                       
          professional corporation (corporation).  Corazon Medina was                 
          secretary of the corporation.  The corporation established a                
          qualified employees' pension plan and trust (plan), which met the           
          requirements of section 401.  During the years in issue,                    
          petitioners were participants in the plan.                                  
               On December 1, 1986, petitioners borrowed $340,000 (loan)              
          from the plan to acquire Sunshine Villa Apartments.  Petitioners            
          executed a promissory note with the following terms:  (1)                   
          Interest at the rate of 10.5 percent per annum is payable                   
          annually; (2) any unpaid interest is added to the principal                 
          amount; and (3) the entire principal amount is due 8 years from             
          the date of the note or, if sooner, upon the sale of Sunshine               
          Villa Apartments.  On August 15, 1991, Mr. Medina executed a                
          document providing that "Building C of Sunshine Villa Apartments            
          * * * [is] assigned to  * * * [the plan]. * * * to ensure that              
          the loan is paid if and when the Sunshine Villa is sold."                   
          Petitioners did not file Form 5330, Return of Excise Taxes                  
          Related to Employee Benefit Plans, for any of the years in issue,           
          nor did they make any payments to the plan pursuant to the terms            
          of the promissory note.                                                     








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