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outflow of funds for the interest paid on the various certifi-
cates of deposit that secured that loan.
With respect to the nature of the relationships disclosed by
the record between (a) the respective rates of interest on BB
Loan No. 2 and the various certificates of deposit that, in form,
secured that loan and (b) the respective dates on which interest
was payable or paid on that loan and those certificates, the
record establishes that, throughout the period during which that
loan was outstanding, the interest rate on that loan was .5
percent above the corresponding interest rate on those certifi-
cates. In addition, petitioner acknowledges on brief that inter-
est was payable on BB Loan No. 2 by Radcliffe to Bangkok Bank
Ltd. through its Los Angeles branch on the same day of the month
on which interest was payable by that bank through that same
branch on the various certificates of deposit that, in form,
secured that loan.109 Consequently, even though, as petitioner
109 Petitioner suggests on brief that the due dates of the
interest on BB Loan No. 2 (as well as on BB Loan No. 3) were made
coextensive with the due dates of the interest on the various
certificates of deposits that secured that loan (as well as BB
Loan No. 3) "apparently" to keep track of the .5 percent dif-
ference between the loan interest rates and the deposit interest
rates. That suggestion serves only to point out the importance
to the persons involved in the BB Loan No. 2 transaction (as well
as the BB Loan No. 3 transaction) of ensuring that the loan
interest payments corresponded with the interest payments on the
various certificates of deposit.
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