- 37 - In Hufnagle v. Commissioner, T.C. Memo. 1986-119, a corporation made payments to three colleges for the educational expenses of the shareholder's children. Although the children were directors of the corporation at the time, the Court found that the payments were not made for bona fide corporate purposes but were made in satisfaction of parental desires. We held that the payments constituted constructive dividends to the shareholder, as we found that an economic benefit had inured to the shareholder and his children. We think that the facts of the cases relied upon by respondent are distinguishable from those before us. In each of the above cases, demonstrable economic benefits accrued to the shareholders and/or their family members from the transfers of funds by the controlled corporations. Corporate funds were used to provide for the maintenance, support, or education of the family members, in satisfaction of obligations with which they or the shareholders would otherwise have been saddled. By contrast, in the instant case, although it is true that expenses for Vance's campaign were paid as a result of the Corporation's contribution, these obligations were the liability of the Committee alone. Nothing in the record suggests that Vance personally guaranteed these debts. Robertson insisted upon the corporate form for the Committee precisely because of the limited liability from creditors it offered.Page: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
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