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          organization is substantially similar.  The most striking fact in           
          both cases is that, notwithstanding the personal desires of the             
          shareholders, the demonstrable economic benefit of such advances            
          accrued to legally distinct entities, and the distributions in no           
          way satisfied the personal obligations of the shareholders or               
          their families.                                                             
               Based on the above discussion and in light of all of the               
          evidence in the record, we hold that the Laniers are not in                 
          receipt of a constructive dividend as a result of the $13,000               
          transfer by the Corporation to the Committee.                               
               We have considered all of the other arguments made by the              
          parties, and, to the extent we have not addressed them, find them           
          to be either irrelevant or without merit.                                   
               To reflect the foregoing and the issue previously conceded,            
                                                  Decisions will be entered           
                                             under Rule 155.                          
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