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V. Analysis of the Transactions at Issue
We note again that, in general, the record in these cases is
poorly developed, inconclusive, and/or unreliable in many re-
spects, including certain material respects.105 Despite the state
of the record in these cases, we have been able to find, inter
alia, that (1) the relationships among the persons involved in
the transactions at issue (viz., the close and amicable business
and family relationships between petitioner and Mme. Koo and, in
the case of the Bank transactions, the desire of the banks in
question to accommodate petitioner, Mme. Koo, Radcliffe and/or
BOT, and the foreign corporations pledging collateral that were
involved in those transactions and their susceptibility to
influence by those persons) are factors we will take into ac-
count in deciding whether to recharacterize those transactions;
(2) petitioner failed to establish a nontax, business purpose for
the form of any of the transactions at issue and acknowledges on
brief a tax avoidance purpose for that form; (3) the record does
not support application of the binding commitment test of the
step transaction doctrine to any of the Bank transactions; and
(4) the role of the banks in question in the Bank transactions
105 The record relating to the transactions involving BB Loan
Nos. 2 and 3 is relatively complete. Although the record relat-
ing to the transactions involving the UB $800,000 Radcliffe loan,
the UB $1,300,000 loan, and the UB $1,830,000 loan are not poorly
developed, there are a number of gaps in the evidence with
respect to each of those transactions.
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