Eugene D. Lanier, Inc. - Page 37

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               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.                                






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