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Respondent points out that title to the house was in Mrs.
Reaves' name until Grant bought the house from Reaves Livestock.
Respondent contends that this fact shows that Mr. and Mrs. Reaves
and not Reaves Livestock bought the house and contends that there
is no evidence that Reaves Livestock lent money to Grant. We
disagree. Mr. and Mrs. Reaves testified that Reaves Livestock
lent Grant the money to buy the house. Reaves Livestock bought
the house. Grant repaid Reaves Livestock, not Mr. and Mrs.
Reaves. Mrs. Reaves took title as a corporate agent. We
conclude that Reaves Livestock bought the Dillon house for Grant,
and that the purchase of the house was not a constructive
dividend to Mr. and Mrs. Reaves.
d. The $55,000 S&J Account Check To Repay Reaves
Livestock for the Beach House Loan
Petitioners contend that the $55,000 Mr. and Mrs. Reaves
obtained from Reaves Livestock for the beach house in 1986 was a
loan, not a constructive dividend. We agree. However, Mr. and
Mrs. Reaves received a constructive dividend when Mrs. Reaves
used funds from the S&J account to repay $55,000 to Reaves
Livestock because that was a personal use of S&J account funds.
6. The Seven Reaves Livestock Checks Payable to S&J
Respondent contends that the seven Reaves Livestock checks
payable to S&J in 1986 are constructive dividends to Mr. and Mrs.
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