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had nontax, business purposes for the form of those transactions,
viz., they desired to (1) earn interest on their deposits and
(2) assist Radcliffe and BOT.
With respect to petitioner's first contention (viz., the
foreign corporations pledging collateral desired to earn interest
on their deposits), the accomplishment of that alleged objective
was in no way dependent upon the completion of the other steps of
the Bank transactions (i.e., the funding by the U.S. banks in
question of the loans to Radcliffe and to BOT and the granting by
the foreign corporations pledging collateral to those banks of
security interests in those deposits). Therefore, the alleged
objective of the foreign corporations pledging collateral of
earning interest on their deposits does not provide a nontax,
business purpose for the other steps of the Bank transactions.
Based on our review of the entire record in these cases,
petitioner has failed to persuade us that the Bank transactions
took the form they did because the foreign corporations pledging
collateral desired to earn interest on their deposits.
With respect to petitioner's second contention (viz., the
foreign corporations pledging collateral wished to assist
Radcliffe and BOT), such a desire, if true, does not by itself
provide a nontax, business purpose for the form of any of the
Bank transactions. For instance, had those corporations desired
to assist Radcliffe and BOT, with the exception of Pioneer and
its subsidiaries Multi-Credit and Mandalay, nothing in the record
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