- 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