Anthony Teong-Chan Gaw as Transferee of Radcliffe Investment LTD. - Page 15

                                                 - 104 -                                                   
            tions will not be ignored or recharacterized for Federal tax pur-                              
            poses solely because relationships exist among the persons in-                                 
            volved in them.  See Goodman v. Commissioner, 74 T.C. 684, 707-                                
            709 (1980), affd. without published opinion 673 F.2d 1332 (7th                                 
            Cir. 1981).                                                                                    
            III. Positions of the Parties With Respect                                                     
                  To the Transactions at Issue72                                                           
                  A.     Bank Transactions73                                                               
                         1.    Respondent's Position                                                       
                  Respondent concedes that loans were, in fact, made to                                    
            Radcliffe and to BOT in the Bank transactions and that those                                   
            corporations paid interest with respect to those loans.  Thus, as                              
            she acknowledges, "This controversy involves the identity of the                               
            true lender of the funds borrowed by BOT and Radcliffe and the                                 
            true recipient of the interest paid by BOT and Radcliffe."  It is                              
            respondent's position that, in substance, one or more of the                                   
            foreign corporations pledging collateral, and not the U.S. banks                               
            in question, made the Bank loans at issue to Radcliffe and to BOT                              
            and Radcliffe and BOT paid interest to those corporations, and                                 


            72  We set forth what we understand to be the main arguments and                               
            contentions that the parties advance in support of their respec-                               
            tive positions.                                                                                
            73  Although the parties' respective positions and the conten-                                 
            tions supporting those positions are discussed by them principal-                              
            ly in terms of the U.S. banks in question, in addressing those                                 
            positions and contentions we have considered all of the banks in                               
            question and their respective roles in the Bank transactions.                                  
            Accordingly, we have, when appropriate, expanded the parties'                                  
            contentions to include all of the banks in question.                                           



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