- 167 -
At first blush, the differences disclosed by the record
between the percentage interest rates on the UB $800,000
Radcliffe loan and the corresponding interest rates on the Multi-
Credit $800,000 deposit and the differences in the dates, at
least the differences exceeding one week, between the respective
dates on which interest was payable on that loan and that deposit
might appear to be factors supporting petitioner's position that
the UB $800,000 Radcliffe loan was, in substance, from Union Bank
to Radcliffe. However, we are unwilling to give any particular
weight to any of those differences, especially when we take into
account (1) that Union Bank and its affiliates Standard Chartered
Bank HK and Standard Chartered Bank, Singapore, desired to accom-
modate, and were susceptible to influence by, petitioner, Mme.
Koo, Radcliffe, and Multi-Credit and (2) petitioner's failure to
establish a nontax, business purpose for the form of the UB
$800,000 Radcliffe loan transaction.
Turning to whether the Multi-Credit $800,000 deposit that
secured the UB $800,000 Radcliffe loan was applied to repay that
loan, petitioner claims on brief that Radcliffe repaid that loan.
However, the record does not disclose (1) the identity of the
person or persons who provided the funds that were used to repay
it or (2) whether or not the Multi-Credit $800,000 deposit was so
applied.
Based upon our examination of the entire record in these
cases, we find that petitioner has failed to carry his burden of
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