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the date on which that loan was repaid, Radcliffe was required to
withhold tax on the full amount of the interest that it, in form,
paid to Bangkok Bank LA branch on BB Loan No. 2 and (2) peti-
tioner, as transferee of Radcliffe, is liable for that withhold-
ing tax liability of Radcliffe.
3. BB Loan No. 3 Transaction
The record establishes that, in form, Bangkok Bank Ltd.
through its Los Angeles branch funded a $1,000,000 loan to
Radcliffe and held a $1,000,000 certificate of deposit in the
name of Double Wealth that secured that loan. The record also
shows that, in form, Bangkok Bank Ltd. through its Los Angeles
branch received interest from Radcliffe with respect to BB Loan
No. 3 and paid interest to Double Wealth on its $1,000,000 de-
posit.
Petitioner asserts, and respondent does not dispute, that
Bangkok Bank Ltd. through its Los Angeles branch had sufficient
funds to make BB Loan No. 3 to Radcliffe without having had the
Double Wealth $1,000,000 CD. Presumably Bangkok Bank Ltd.
through that same branch also had sufficient funds to pay inter-
est on the Double Wealth $1,000,000 CD without its having re-
ceived interest from Radcliffe with respect to BB Loan No. 3.
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, and
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