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issue. Specifically, in its income tax returns for the years at
issue, Radcliffe claimed the following deductions for interest
paid to Bangkok Bank LA branch:
Year Amount
1984 $73,791
1985 194,289
1986 211,719
In its income tax returns for the years at issue, Radcliffe
claimed the following deductions for interest paid to Union Bank:
Year Amount
1984 $144,427
1985 220,171
1986 120,008
In its income tax returns for the years at issue, BOT
claimed the following deductions for interest paid to Union Bank:
Year Amount
1984 $167,448
1985 233,853
1986 119,260
OPINION
In determining that petitioner is liable for the deficien-
cies in, additions to, and penalties on withholding tax that she
determined with respect to Radcliffe and BOT, respondent relies
on the transferee liability provisions of section 6901. Peti-
tioner does not dispute that he would be liable as a transferee
of each of those taxpayers under section 6901 for those deficien-
cies in, additions to, and penalties on tax in the event the
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