Epco, Inc. and Subsidiaries - Page 8

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            from McArthy not a sewer pipeline, but, rather, the direct                                     
            benefit of the cash disbursements.4  Thus, as we stated in our                                 
            opinion in Epco, Inc. & Subs. v. Commissioner, supra, the General                              
            Explanation is irrelevant to the facts in this case.                                           
                  Having reconsidered petitioner's alternative argument and                                
            addressed the merits thereof, we deny petitioner's Motion to                                   
                  To reflect the foregoing,                                                                
                                                              An appropriate order will                    
                                                        be issued.                                         

            4            One of the direct benefits received by petitioner as a                            
            result of McArthy's contributions was that the funds went to pay                               
            contractors and subcontractors to whom petitioner was directly                                 

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