Anthony Teong-Chan Gaw as Transferee of Radcliffe Investment LTD. - Page 160

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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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