- 114 -
of those corporations.80 She further asserts on brief that the
banks in question desired to accommodate, and were susceptible to
influence by, petitioner, Radcliffe and/or BOT, and the foreign
corporations pledging collateral. Petitioner contends that Mme.
Koo controlled the foreign corporations pledging collateral,
except Merit and Pempire, and that the banks in question were
commercial banks and were not controlled by Radcliffe, BOT, or
the foreign corporations pledging collateral.
Based on our review of the entire record in these cases, we
find that, with the exception of Pempire in which the parties
stipulated that petitioner owned a controlling stock interest no
later than July 1984,81 the evidence in the record is insuffi-
cient to enable us to determine whether, during the years at
issue, petitioner or Mme. Koo owned a controlling stock interest
in, or otherwise controlled, any of the foreign corporations
pledging collateral.82
79(...continued)
With respect to Pempire, the deposit of which was pledged as
collateral for the UB $1,830,000 loan made to BOT in August 1984,
as stated supra note 76, the parties stipulated that petitioner
acquired all of the stock of Pempire no later than July 1984.
80 Respondent does not point to any portion of the record sup-
porting her allegation on brief that, and nothing in the record
establishes whether or not, petitioner was a director and/or an
officer of Intercontinental and Merit during the years at issue.
81 The parties appear to agree on brief that petitioner's mother
controlled Merit at all relevant times. See supra note 76 and
first paragraph note 79.
82 The insufficiency of the record is illustrated by the follow-
(continued...)
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