regulation, is whether Coppola’s assignment/pledge of a portion of the ORPA resulted in a deemed taxable distribution of that portion, result ing in its loss of exempt status under Texas law. This is indeed the result because, as the district court held, a taxpayer’s [rjeceipt of a deemed distribution results in a tax consequence to Coppola. See 26 U.S.C. § 72(p) (providing as a general rule that all participant loans will be treated as “deemed” taxable distributions); 26 C.F.R. § 1.72(p)-l. Therefore, funds that are deemed distributed are no longer part of a tax-exempt plan. While the funds may never have been actually distributed to Coppola, he did receive a deemed distribution, which creates a tax liability by operation of law. See also In re Sallee, 286 F.3d 878, 902 (6th Cir.2002) (<HOLDING>). Because Texas Property Code § 42.0021
holding that the owner of an equitable interest in property in the form of a land contract can grant a mortgage on that interest under ohio law holding that even assuming government was a party in interest in the delaware case and that the party in interest status was sufficient to make the delaware plan binding upon it the government did not receive adequate notice that confirmation might affect its pecuniary interest holding that a  72p assignment of an interest in a esop is a deemed distribution of the interest eliminating its taxdeferred status holding that when an oversecured creditor seeks interest on its claim courts apply the interest rate provided for in the contract holding that prejudgment interest may include compound interest