Ralf Zacky - Page 8

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                     Date      Principal    Interest    Amount Involved               
                    1/1/96     $203,241       10%          $20,324                    
                    1/1/97      223,565       10            22,356                    
                    1/1/98      245,922       10            24,592                    
                    1/1/99      270,514       10            27,051                    
                    1/1/00      297,565       10            29,756                    
          124,079                                                                     
          Respondent noted that section 53.4941(e)-1(e)(1), Foundation                
          Excise Tax Regs., treats prohibited transaction loans as                    
          occurring on the first day of each taxable year in the taxable              
          period after the year in which the loan occurs and determined on            
          the basis of these regulations that petitioner owed first-tier              
          excise taxes as follows:                                                    
               1996            1997      1998      1999      2000                     
               $1,016   $1,016    $1,016    $1,016    $1,016                          
          –-     2,236     2,236     2,236     2,236                                  
               --       --      3,689     3,689     3,689                             
               –-       --        –-      4,058     4,058                             
                 –-       –-        --        –-      4,464                           
          1,016    3,252     6,941    10,999   15,463                                 
          Respondent also determined on the basis of these regulations that           
          petitioner owed a second-tier excise tax of $124,079 for 2001.              
               On January 19, 1994, Aspects filed a voluntary petition for            
          bankruptcy.  Aspects stated on that petition that it owed                   
          $195,000 to the plan and that the plan was an unsecured creditor.           
          On February 6, 1995, the bankruptcy court overseeing the                    
          bankruptcy proceeding confirmed Aspects’s “First Amended plan of            









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