MEMORANDUM OPINION
FAY, Judge:
By notice of deficiency dated July 15, 1993, respondent determined deficiencies in Jo B. Gray's and Thomas S. Gray's Federal income tax for the taxable years 1988 and 1989 in the amounts of $28,486 and $37,657, respectively. The issue for decision is whether $50,000 of an $88,774.50 loan from Tri-State Machinery of El Paso, Inc. Profit Sharing Plan & Trust to Thomas S. Gray in 1988 is a taxable distribution. We hold that...
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