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personal benefit to the shareholder to render the distribution a
constructive dividend to the shareholder. See Hardin v. United
States, 461 F.2d at 872; Cirelli v. Commissioner, 82 T.C. 335
(1984); Marcy v. Commissioner, T.C. Memo. 1994-534; Synder v.
Commissioner, T.C. Memo. 1983-692; Proctor v. Commissioner, T.C.
Memo. 1981-436; Fenn v. Commissioner, T.C. Memo. 1980-229. We
hold that individual petitioners personally benefited from the
transfer to Lily, and that amount is a constructive dividend from
Eastimpex to individual petitioners.
Based on the above reasoning, we also find that the $116,687
paid from the First Pacific account to Daniel Chen under the 1986
Agreement constitutes a constructive dividend to individual
petitioners. In addition, we find that the check issued from the
Coast account payable to Priscilla in the amount of $86,651 is a
constructive dividend to individual petitioners. We do not find
petitioner husband's uncorroborated testimony that Lily
ultimately received the money from this check to be credible.
Even if Lily did receive the money, individual petitioners did
not present any evidence that the money was repaid to Shin. Nor
have individual petitioners proved a business purpose for this
check. Regardless of whether Lily or Priscilla received the
money, we find that individual petitioners received a personal
benefit because the money was given to one of their relatives
without a proven business purpose. Thus, the check issued to
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