Anthony Teong-Chan Gaw as Transferee of Radcliffe Investment LTD. - Page 66

                                                 - 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.                                        





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