- 27 -                                         
          inability to repay the loan resulted from a downturn in the real            
          estate market and not from impropriety on its part.  We found               
          that although the loan failed to meet the prudent investor test,            
          it was an isolated violation of that test, did not exhibit                  
          indifference to the continued well-being of the plan, and was not           
          an attempt to manipulate the plan's assets for the benefit of               
          persons other than the plan's beneficiaries.  We therefore found            
          that the loan did not violate the exclusive benefit rule.                   
          Accordingly, we concluded that the extension of the loan did not            
          cause the plan to fail to satisfy the requirements of sections              
          401(a) and 501(a).                                                          
               Our examination of the facts in this case leaves no doubt              
          that the Defined Benefit Plan was not managed for the exclusive             
          benefit of the employees.  While the detailed facts of this case            
          are not identical with those in Winger's Depart. Store, Inc. v.             
          Commissioner, supra, or in Ada Orthopedic, Inc. v. Commissioner,            
          supra, the ultimate thrust of those cases is equally applicable             
          here.  The facts in Winger's and Ada Orthopedic reveal investment           
          philosophies that were not aimed primarily at providing benefits            
          for the employees and their beneficiaries in general but instead            
          were aimed at benefiting the plan sponsors or certain                       
          individuals.  Indeed, the investment practices in those cases               
          involved flagrant violations of the exclusive benefit rule.                 
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