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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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