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Date of Loan Obligee Loan Amount Interest Rate
2/8/84 Defined Benefit Plan $13,000 11%
8/27/85 Defined Benefit Plan 50,000 12
12/3/85 Defined Benefit Plan 5,500 10
1/3/86 Defined Benefit Plan 14,500 10.5
2/12/88 Defined Benefit Plan 20,000 9.75
12/9/88 Defined Benefit Plan 2,000 11.5
Total 105,000
These six notes all fail to state when payments are due or
when repayments should be made. None of the six installment
notes require Morrissey to provide security or collateral for the
loans. None of the installment notes state a maturity date.
The administrative record provided in this case contains no
evidence that Morrissey made any repayments on any of the six
loans from the Defined Benefit Plan, and we so find. In
Morrissey v. Commissioner, T.C. Memo. 1998-443, we found that on
October 19, 1990, Morrissey transferred to the Money Purchase
Plan his 50-percent interest in two parcels of unencumbered real
estate sited in Southampton, New York. We stated: "The record
does not show that * * * [Morrissey] ever transferred any asset
to the * * * [Defined Benefit Plan] in repayment of moneys that
he borrowed from it." We also stated: "Indeed, it appears that
* * * [Morrissey] continues to owe the * * * [Defined Benefit
Plan] the money (with interest) that it lent to him because he
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Last modified: May 25, 2011