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may be ignored or recharacterized even though they were otherwise
engaged in business and were not controlled by Radcliffe, BOT, or
the foreign corporations pledging collateral.
Additional factors that we consider relevant to our analysis
of the transactions at issue include (1) the nature of the rela-
tionships, if any, between (a) the respective rates of interest
on the loans at issue and the cash deposits that secured them and
(b) the respective dates on which interest was payable or paid on
those loans and deposits and (2) whether the respective cash
deposits that secured the loans at issue were applied to repay
those loans. With respect to the last factor, it is significant
that there is nothing in the record to suggest that Radcliffe or
BOT was in default on any of the Bank loans at issue at the time
such loans were repaid, and petitioner does not attempt to ex-
plain why any of those loans was repaid in the manner in which it
was. Petitioner does not argue, and the record does not support
a finding, that the manner in which repayment of any of the Bank
loans was made was attributable to any financial or other diffi-
culties that he, Radcliffe or BOT, as the case may be, and/or
NMSC or 300 Montgomery Associates, as the case may be, were
experiencing at the time any of those loans was repaid. Instead,
petitioner alleges on brief that Radcliffe and BOT had
sufficientnet worth and cash flow to repay their respective Bank
loans. If the role of the foreign corporations pledging collat-
eral in the various Bank transactions had, in substance, been
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