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Singapore, presumably paid interest to Forward on its $570,000
deposit.
Petitioner asserts, and respondent does not dispute, that
Union Bank had sufficient funds to make the UB $570,000 pre-March
1984 loan to BOT without its affiliate Standard Chartered Bank HK
having had the Merit $570,000 deposit. Presumably Standard
Chartered Bank HK also had sufficient funds to pay interest on
the Merit $570,000 deposit without its affiliate Union Bank
having received interest from BOT with respect to the UB $570,000
pre-March 1984 loan. Nor does respondent dispute petitioner's
assertion that Union Bank had sufficient funds to renew the
$570,000 loan to BOT in March 1984 without its affiliate Standard
Chartered Bank, Singapore, having had the Forward $570,000 depos-
it. Presumably Standard Chartered Bank, Singapore, also had
sufficient funds to pay interest on the Forward $570,000 deposit
without its affiliate Union Bank having received interest from
BOT with respect to the UB $570,000 renewed loan.
Nonetheless, we are satisfied from the record before us,
including (1) the relationships of (a) Union Bank and its affili-
ates Standard Chartered Bank HK and Standard Chartered Bank,
Singapore, with petitioner, Mme. Koo, BOT, Merit, and Forward and
(b) petitioner with Mme. Koo and (2) the lack of a nontax, busi-
ness purpose for the form of the UB $570,000 pre-March 1984 and
renewed loan transactions, that Union Bank (1) through its affil-
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