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deposit. This is because the record is inadequate. In this
regard, while the record shows certain facts relating to that
inquiry with respect to BB Loan No. 1 (viz., the interest rate
and actual interest rate percentages that were in effect for the
period during which that loan was outstanding and the dates on
which interest was payable and paid on that loan), the record
does not disclose those facts with respect to the Intercontinen-
tal $450,000 deposit.
Turning to whether the Intercontinental $450,000 deposit
that secured BB Loan No. 1 was applied to repay that loan, peti-
tioner admits on brief, and respondent does not dispute, that on
June 30, 1986, the Intercontinental $450,000 deposit was applied
to reduce the then outstanding $600,000 balance of BB Loan No. 1
to $150,000.
Based upon our examination of the entire record in these
cases, and bearing in mind the substantial gaps in the evidence
with respect to the BB Loan No. 1 transaction, we find that
petitioner has failed to carry his burden of showing that respon-
dent erred in determining that Radcliffe was required to withhold
tax on the interest that it, in form, paid to Bangkok Bank LA
branch on $450,000 of Bangkok Bank Loan No. 1 for the period
during which the Intercontinental $450,000 deposit served, in
form, as security for that loan (viz., from on or about May 17,
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