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dent's determinations that (1) for the period that commenced on
or about May 17, 1984, the date on which BB Loan No. 1 was fund-
ed, and ended on June 30, 1986, the date on which the Interconti-
nental $450,000 deposit was applied to reduce the then outstand-
ing balance of that loan, Radcliffe was required to withhold tax
on the full amount of the interest that it, in form, paid to
Bangkok Bank LA branch on $450,000 of BB Loan No. 1 and (2) peti-
tioner, as transferee of Radcliffe, is liable for that withhold-
ing tax liability of Radcliffe.
2. BB Loan No. 2 Transaction
The record establishes that, in form, Bangkok Bank Ltd.
through its Los Angeles branch funded a $1,625,000 loan to
Radcliffe, later increased to $2,025,000, and held various cer-
tificates of deposit initially in the name of Traveluck and
thereafter in the name of Double Wealth that secured that loan.
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. 2 and paid interest initially to Traveluck
and thereafter to Double Wealth on their respective certificates
of 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. 2 to Radcliffe without having had the
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