Anthony Teong-Chan Gaw as Transferee of Radcliffe Investment LTD. - Page 60

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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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