Prohibited Transaction -- Loan to Corporation

[chris]

Twelve professionals are shareholders in Real Estate Corporation (REC). Same twelve professionals are also each a shareholder in his or her separate professional corporation that leases space from RAC. Each of the separate professional corporations maintains a PSP and each of the twelve professionals is also a trustee of the respective PSP maintained by his or her corporation. REC has a substantial loan coming due and the twelve professionals have come up with the idea of having each of their respective PSP's make a loan to REC pro-rata in order to allow REC to be able to pay off the loan. Based on the mechanics it appears that while it is a loan §4975©(1)(B) is not the problem unless you stretch "indirect" in the intro language of §4975©(1). Rather it appears that §4975©(1)(D) or (E) would make this a prohibited transaction in that the loan transaction would be "for the benefit of" each of the twelve professionals (D) or would constitute an act whereby each of the twelve professionals as trustee of his or her respective PSP would be "dealing with the assets of a plan in his own interest or for his own account" (E). Any thoughts greatly appreciated.