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currency transaction for its clients. LTD engaged in four types
of currency transactions. Moreover, petitioners do not point to
any evidence in the record that would support petitioners'
asserted basis for apportionment. Petitioners offered no proof
at trial concerning the transfer fee that would "normally" be
charged under such circumstances. Generally, we do not grant
reconsideration to resolve issues which could have been raised
during the prior proceedings because the parties cannot try their
cases with hindsight. CWT Farms, Inc. v. Commissioner, 79 T.C.
1054, 1057 (1982), affd. 755 F.2d 790 (11th Cir. 1985), and cases
cited therein. Accordingly, as to the currency exchange
transactions income, we do not reconsider our holdings with
respect to the section 482 allocations of income to INC.
3. Client Incorporation and Trust Creation Fees
Petitioners seek reconsideration of the section 482
allocations of LTD's income from client incorporation fees to
INC. Petitioners argue that the payments to third party lawyers
and fiduciaries are merely repayment of funds LTD advanced to the
contract lawyers or professionals and should therefore be
deducted in the calculation of the arm's-length fee for INC's
services in connection with the client incorporation fees.
Relying on respondent's original allocations in the notice of
deficiency based on net amounts, petitioners contend that the
section 482 allocations should be reduced by the "direct costs",
which include the payments that LTD made to third party lawyers
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