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each month. Interest on that loan was paid on the following
dates:
Dec. 13, 1985
Jan. 14, 1986
Feb. 13, 1986
Mar. 10, 1986
Apr. 14, 1986
May 12, 1986
June 16, 1986
July 14, 1986
Aug. 15, 1986
Sept. 12, 1986
Pursuant to the instructions of petitioner on behalf of
Double Wealth, Bangkok Bank LA branch credited monthly to Double
Wealth's account with that branch the interest payable on the
Double Wealth $1,000,000 CD for the period December 1985 through
May 1986. Interest on that certificate of deposit was paid on
the following dates:
Dec. 11, 1985
Jan. 13, 1986
Feb. 11, 1986
Mar. 11, 1986
Apr. 11, 1986
May 13, 1986
In the May 26, 1986 and June 9, 1986 instructions, Ms. Gaw
and petitioner, respectively, instructed Bangkok Bank LA branch
on behalf of Double Wealth to remit on a monthly basis the
interest payable on the Double Wealth $1,000,000 CD through
Standard Chartered Bank, New York, to the account of Vidda that
was maintained in Standard Chartered Bank HK. Pursuant to those
instructions, on June 11, 1986, July 14, 1986, and August 12,
1986, Bangkok Bank LA branch remitted the interest payable on
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