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funds used to repay the UB $325,000 loan were wired to Union Bank
from Standard Chartered Bank HK, the same affiliate of Union Bank
in which the Forward $325,000 deposit that secured that loan was
maintained. Thus, it appears reasonable to infer that the For-
ward $325,000 deposit could have been used to repay that loan,
and petitioner has not shown that that deposit was not so ap-
plied.
Based upon our examination of the entire record in these
cases, and bearing in mind the substantial gaps in the evidence
with respect to the UB $325,000 loan transaction, we find that
petitioner has failed to carry his burden of showing that respon-
dent erred in determining that Radcliffe was required to withhold
tax on the interest that it, in form, paid to Union Bank as part
of that transaction.117 Accordingly, we sustain respondent's
determinations that (1) for the period that commenced in April
1984 on the date on which the UB $325,000 loan was funded and
ended on July 10, 1986, the date on which that loan was repaid,
Radcliffe was required to withhold tax on the full amount of the
interest that it, in form, paid to Union Bank on the UB $325,000
loan and (2) petitioner, as transferee of Radcliffe, is liable
for that withholding tax liability of Radcliffe.
117 See first paragraph supra note 108 for our views on peti-
tioner's alternative argument about portfolio interest.
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