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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-
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