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on the Multi-Credit $800,000 deposit without their affiliate
Union Bank's having received interest from Radcliffe with respect
to the UB $800,000 Radcliffe 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, Radcliffe, and Multi-Credit
and (b) petitioner with Mme. Koo and (2) the lack of a nontax,
business purpose for the form of the UB $800,000 Radcliffe loan
transaction, that Union Bank through its affiliate Standard Char-
tered Bank HK and thereafter its affiliate Standard Chartered
Bank, Singapore, had a source (viz., the Multi-Credit $800,000
deposit) for the UB $800,000 NMSC loan that it or one of its
branches or predecessors in San Francisco funded and that was
assumed by Radcliffe. We are also satisfied from that record
that Standard Chartered Bank HK and thereafter Standard Chartered
Bank, Singapore, through their affiliate Union Bank had a source
(viz., the interest paid by Radcliffe to Union Bank on the UB
$800,000 Radcliffe loan) for the interest they paid on the Multi-
Credit $800,000 deposit. Moreover, Union Bank through its affil-
iate Standard Chartered Bank HK and thereafter its affiliate
Standard Chartered Bank, Singapore, had an inflow of funds (viz.,
the Multi-Credit $800,000 deposit) that was sufficient to cover
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