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as of September 12, 1986, be transferred to Bangkok Bank HK
branch for the account of Double Wealth. Interest on that cer-
tificate of deposit was paid on September 12, 1986. (Herein-
after, BB $1,625,000 Loan No. 2, the $400,000 increase in that
loan, and BB $2,025,000 Loan No. 2 as renewed will be referred to
collectively as BB Loan No. 2.)
C. BB Loan No. 3
Petitioner 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 (BB
Loan No. 3). Bangkok Bank HK branch complied with that request,
and Bangkok Bank LA branch funded a $1,000,000 loan to Radcliffe
on November 12, 1985. That loan was due on November 12, 1986.
The proceeds of BB Loan No. 3 were credited to the account of
Bangkok Bank HK branch with Bangkok Bank LA branch.
To document that loan, petitioner signed on behalf of
Radcliffe a promissory note that was made payable to Bangkok Bank
LA branch and that was in the same amount as that loan. The
continuing, unlimited, unconditional promise and the general
security agreement signed by petitioner on behalf of Radcliffe as
part of the BB Loan No. 1 transaction applied to BB Loan No. 3.
Pursuant to a decision on October 28, 1985, of the board of
directors of Double Wealth (viz., petitioner, Ms. Gaw, and Mme.
Koo), a $1,000,000 certificate of deposit issued by Bangkok Bank
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