- 38 -
The corporate form is not to be disregarded lightly, and the
Court declines to do so here. See Moline Properties, Inc. v.
Commissioner, 319 U.S. 436 (1943). We note in this regard that
the Committee maintained its own bank account and kept its own
accounting and financial records. In addition, the check from
the Corporation was endorsed "Vance E. Lanier Inc., Committee to
Elect Vance Lanier" rather than by Vance personally, and the
funds were deposited in the Committee's own account.
We believe that the facts of Knott v. Commissioner, supra,
while not identical to those of the present matter, are
nonetheless analogous. In that case, a corporation and its
controlled subsidiaries made below-market sales of real estate to
its shareholders' eponymous charitable foundation. The
shareholders did not receive money or other property from the
corporations; their personal debts were not assumed by the
corporations; the corporations did not purchase and maintain
property for the shareholders' personal use and enjoyment; and
the shareholders' family members did not obtain property or other
tangible economic benefits as a result of the below-market sales.
We held that controlling shareholders or their families must
receive property or other economic benefit from the charitable
contributions before constructive dividends will be imputed. Id.
at 693-694.
While we are aware that the Committee was not a charitable
foundation, for our present purposes we think that a political
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