Anthony Teong-Chan Gaw as Transferee of Radcliffe Investment LTD. - Page 76

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            were susceptible to influence by, petitioner, Mme. Koo,                                        
            Radcliffe, BOT, Pioneer and its wholly owned subsidiaries Multi-                               
            Credit and Mandalay, Merit, Forward, and Pempire.                                              
                  F.     Petitioner                                                                        
                  Petitioner was a U.S. citizen during the years at issue.                                 
            Prior to and during those years, petitioner and Mme. Koo had                                   
            close and amicable business and family relationships.  Thus, for                               
            example, petitioner was able to borrow from, and give guarantees                               
            for more than he was worth to, banks in Hong Kong because those                                
            banks knew that Mme. Koo would honor his obligations if the need                               
            arose.                                                                                         
                  At the time of the transactions at issue, petitioner was                                 
            familiar with the U.S. withholding tax requirements applicable to                              
            interest from a U.S source that was paid to foreign corporations.                              
            II. Transactions Involving Bangkok Bank Ltd.                                                   
                  A.     BB Loan No. 1                                                                     
                  By letter dated May 16, 1984 (May 16, 1984 letter), peti-                                
            tioner requested on behalf of Radcliffe that the Hong Kong branch                              
            of Bangkok Bank Ltd. arrange for the Los Angeles branch of that                                
            bank to fund a loan of $1,000,000 to Radcliffe.  Bangkok Bank HK                               
            branch complied with that request, and Bangkok Bank LA branch                                  
            funded a $1,000,000 loan to Radcliffe on or about May 17, 1984                                 
            (original BB Loan No. 1).  That loan was due on May 17, 1985.                                  
            The proceeds of the original BB Loan No. 1 were used to reimburse                              
            Bangkok Bank HK branch for settling a claim by Hong Kong and                                   




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