Stephen Daryl Royal - Page 4

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               Petitioner was sent a notice dated September 4, 2002, with             
          respect to each of petitioner’s loans.  Such notice informed                
          petitioner that he was required to repay in full by December 3,             
          2002, the loan to which such notice pertained and that if he did            
          not do so, a taxable distribution would be declared with respect            
          to the unpaid principal and unpaid interest to September 16,                
          2002, with respect to such loan.  Petitioner did not repay                  
          petitioner’s loans.                                                         
               On September 23, 2002, the Federal Thrift Savings Plan sent            
          petitioner two letters (collectively, September 23, 2002 let-               
          ters), one of which pertained to petitioner’s $10,477.89 loan               
          (September 23, 2002 letter pertaining to petitioner’s $10,477.89            
          loan) and the other of which pertained to petitioner’s $15,462.60           
          loan (September 23, 2002 letter pertaining to petitioner’s                  
          $15,462.60 loan).  The September 23, 2002 letter pertaining to              
          petitioner’s $10,477.89 loan stated in pertinent part:                      
               You were sent a notice dated 09/04/02, informing you                   
               that, because you separated after your Thrift Savings                  
               Plan (TSP) loan was issued, you must repay your loan in                
               full by 12/03/02, or a taxable distribution would be                   
               declared.  Because you forfeited your right to repay                   
               the loan in full, effective 09/16/02, a taxable distri-                
               bution in the amount of $10,477.89 has been declared in                
               connection with the unpaid principal and unpaid inter-                 
               est to 09/16/02, on * * * [petitioner’s $10,477.89]                    
               loan.                                                                  
          The September 23, 2002 letter pertaining to petitioner’s                    
          $15,462.60 loan stated in pertinent part:                                   
               You were sent a notice dated 09/04/02, informing you                   





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