Robert A. Stanford and Susan Stanford - Page 18

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          the banking activity of Guardian Bank.                                      
               The credible evidence before us, however, is sparse and                
          establishes only that Stanford Financial performed administrative           
          and management support services for Guardian Bank.  It does not             
          establish that Stanford Financial engaged in any banking or                 
          financing activity described in section 1.864-4(c)(5)(i), Income            
          Tax Regs.  Administrative and management services of the                    
          generalized type conducted by Stanford Financial do not qualify             
          as banking or financing activity for this purpose.  Stanford                
          Financial did not have a banking license.                                   
               Petitioners also argue that Stanford Financial provided                
          services to Guardian Bank "similar" to the business of banking.             
          We are not persuaded on this record that the administrative and             
          management services performed by Stanford Financial for Guardian            
          Bank qualify as activities similar to those of a banking or                 
          financing business.                                                         
               The manner by which petitioner structured the ownership                
          relationship between Guardian Bank, Guardian Services, and                  
          Stanford Financial, as petitioners allege, may have related to              
          anticipated changes in the laws of Montserrat relating to                   
          banking.  On the evidence before us, however, anticipated changes           
          in Montserrat law do not provide a sufficient basis to ignore               
          differences between the banking activity of Guardian Bank and the           
          administrative and management activities of Stanford Financial.             
               We conclude that Stanford Financial was not engaged in a               

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