- 150 - points out, Bangkok Bank Ltd. through its Los Angeles branch could be considered to have "owned" the interest that Radcliffe, in form, paid to it with respect to BB Loan No. 2, the inflow of those interest payments to it was matched in both amount (except for the .5 percent difference between the interest rate on that loan and the interest rate on each of the various certificates of deposit that, in form, secured that loan) and time by the outflow of interest payments by it initially to Traveluck and thereafter to Double Wealth on the various certificates of deposit that secured BB Loan No. 2. Turning to whether the Double Wealth $2,025,000 CD that secured BB Loan No. 2 was applied to repay that loan, the record discloses that that loan was repaid on September 12, 1986, with the proceeds represented by that certificate of deposit. Based on our examination of the entire record in these cases, we find that petitioner has failed to carry his burden of showing that respondent erred in determining that Radcliffe was required to withhold tax on the interest that it, in form, paid to Bangkok Bank LA branch as part of the BB Loan No. 2 transac- tion.110 Accordingly, we sustain respondent's determinations that (1) for the period that commenced on June 11, 1985, the date on which BB Loan No. 2 was funded, and ended on September 12, 1986, 110 See first paragraph supra note 108 for our views on peti- tioner's alternative argument about portfolio interest.Page: Previous 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 157 158 159 Next
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