Ralf Zacky - Page 7

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                         (5) the procedure under the program for                      
                         determining a reasonable rate of interest;                   
                         (6) the types of collateral which may secure a               
                         Participant loan; and                                        
                         (7) the events constituting default and the steps            
                         that will be taken to preserve plan assets.                  
                         Such Participant loan program shall be                       
                    contained in a separate written document which,                   
                    when properly executed, is hereby incorporated by                 
                    reference and made a part of the plan.                            
               Petitioner has never filed a Form 5330, Return of Excise               
          Taxes, for any period relevant herein.  The plan filed a Form               
          5500-C/R, Return/Report of Employee Benefit plan, for its plan              
          years ended March 31, 1991, 1992, 1993, and 1995.  The plan has             
          not filed a Form 5500-C/R for any plan year thereafter.                     
               The plan reported on its Form 5500-C/R for its plan year               
          ended March 31, 1995, that it had as of March 31, 1995, “Other”             
          investments of $203,241.  Respondent determined that these                  
          investments were the three loans, that each of the three loans              
          was a prohibited transaction under section 4975, and that the               
          principal of the three loans totaled $203,241 as of January 1,              
          1996.  Respondent also determined that a “stated interest rate”             
          of 10 percent applied to each subject year for purposes of                  
          computing the “amount involved” under section 4975(a) and that,             
          on the basis of this 10-percent rate, the amounts involved for              
          the subject years were as follows:                                          








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