- 148 - deposit represented by the certificates of deposit that were initially in the name of Traveluck and thereafter Double Wealth. Presumably Bangkok Bank Ltd. through that same branch also had sufficient funds to pay interest on the certificates of deposit that secured BB Loan No. 2 without its having received interest from Radcliffe with respect to BB Loan No. 2. Nonetheless, we are satisfied from the record before us, including (1) the relationships of (a) Bangkok Bank Ltd. and its Los Angeles branch with petitioner, Mme. Koo, Radcliffe, Traveluck, and Double Wealth and (b) petitioner with Mme. Koo and (2) the lack of a nontax, business purpose for the form of the BB Loan No. 2 transaction, that Bangkok Bank Ltd. through its Los Angeles branch (1) had a source (viz., the certificates of depos- it initially in the name of Traveluck and thereafter Double Wealth) for BB Loan No. 2 and (2) had a source (viz., the inter- est paid by Radcliffe on BB Loan No. 2) for the interest it paid on the various certificates of deposit that secured that loan. Moreover, Bangkok Bank Ltd. through its Los Angeles branch (1) had an inflow of funds (viz., the certificates of deposit initially in the name of Traveluck and thereafter Double Wealth) that was sufficient to cover its outflow of funds for BB Loan No. 2 and (2) had an inflow of funds (viz., the interest paid by Radcliffe on BB Loan No. 2) that was sufficient to cover itsPage: Previous 138 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 157 Next
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