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to Forward on its $325,000 deposit.
Petitioner asserts, and respondent does not dispute, that
Union Bank had sufficient funds to make the UB $325,000 loan to
Radcliffe without its affiliate Standard Chartered Bank HK having
had the Forward $325,000 deposit. Presumably Standard Chartered
Bank HK also had sufficient funds to pay interest on the Forward
$325,000 deposit without its affiliate Union Bank's having re-
ceived interest from Radcliffe with respect to the UB $325,000
loan.
Nonetheless, we are satisfied from the record before us,
including (1) the relationships of (a) Union Bank and its affili-
ate Standard Chartered Bank HK with petitioner, Mme. Koo,
Radcliffe, and Forward and (b) petitioner with Mme. Koo and
(2) the lack of a nontax, business purpose for the form of the UB
$325,000 loan transaction, that (1) Union Bank through its affil-
iate Standard Chartered Bank HK had a source (viz., the Forward
$325,000 deposit) for the UB $325,000 loan it funded and
(2) Standard Chartered Bank HK through its affiliate Union Bank
had a source (viz., the interest paid by Radcliffe to Union Bank
on the UB $325,000 loan) for the interest it presumably paid on
the Forward $325,000 deposit. Moreover, (1) Union Bank through
its affiliate Standard Chartered Bank HK had an inflow of funds
(viz., the Forward $325,000 deposit) that was sufficient to cover
its outflow of funds for the UB $325,000 loan to Radcliffe and
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