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standby letter of credit guaranteeing that loan and held a
$450,000 deposit in the name of Intercontinental that, in turn,
secured that standby letter of credit and thereby secured that
loan to the extent of $450,000. The record also shows that, in
form, Bangkok Bank Ltd. through its Los Angeles branch received
interest from Radcliffe with respect to BB Loan No. 1 and, al-
though the record is silent on this point, Bangkok Bank Ltd.
through its Hong Kong branch presumably paid interest to Inter-
continental on its $450,000 deposit.
Petitioner asserts, and respondent does not dispute, that
Bangkok Bank Ltd. through its Los Angeles branch had sufficient
funds to make BB Loan No. 1 to Radcliffe without that bank
through its Hong Kong branch having had the Intercontinental
$450,000 deposit. Presumably Bangkok Bank Ltd. through its Hong
Kong branch also had sufficient funds to pay interest on the
Intercontinental $450,000 deposit without that bank through its
Los Angeles branch having received interest from Radcliffe with
respect to BB Loan No. 1.
Nonetheless, we are satisfied from the record before us,
including (1) the relationships of (a) Bangkok Bank Ltd. and its
Los Angeles and Hong Kong branches with petitioner, Mme. Koo,
Radcliffe, and Intercontinental and (b) petitioner with Mme. Koo
and (2) the lack of a nontax, business purpose for the form of
the BB Loan No. 1 transaction, that Bangkok Bank Ltd. (1) through
its Hong Kong branch had a source (viz., the Intercontinental
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