Anthony Teong-Chan Gaw as Transferee of Radcliffe Investment LTD. - Page 68

                                                 - 152 -                                                   
            Double Wealth and (b) petitioner with Mme. Koo and (2) the lack                                
            of a nontax, business purpose for the form of the BB Loan No. 3                                
            transaction, that Bangkok Bank Ltd. through its Los Angeles                                    
            branch (1) had a source (viz., the Double Wealth $1,000,000 CD)                                
            for BB Loan No. 3 that it funded and (2) had a source (viz., the                               
            interest paid by Radcliffe on BB Loan No. 3) for the interest it                               
            paid on the Double Wealth $1,000,000 CD.  Moreover, Bangkok Bank                               
            Ltd. through its Los Angeles branch (1) had an inflow of funds                                 
            (viz., the Double Wealth $1,000,000 CD) that was sufficient to                                 
            cover its outflow of funds for BB Loan No. 3 and (2) had an                                    
            inflow of funds (viz., the interest paid by Radcliffe on BB Loan                               
            No. 3) that was sufficient to cover its outflow of funds for the                               
            interest paid on the Double Wealth $1,000,000 CD.                                              
                  With respect to the nature of the relationships disclosed by                             
            the record between the respective rates of interest on BB Loan                                 
            No. 3 and the Double Wealth $1,000,000 CD, the record establishes                              
            that, throughout the period during which that loan was outstand-                               
            ing, the interest rate on that loan was set at .5 percent above                                
            the corresponding interest rate on that certificate.  In addi-                                 
            tion, petitioner acknowledges on brief that interest was payable                               
            on BB Loan No. 3 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 certifi-                              








Page:  Previous  142  143  144  145  146  147  148  149  150  151  152  153  154  155  156  157  158  159  160  161  Next

Last modified: May 25, 2011