- 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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