Anthony Teong-Chan Gaw as Transferee of Radcliffe Investment LTD. - Page 63

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            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 its                                   








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