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was "principally organized to do in order to realize profit", was
to enable Mexican nationals to invest their capital in non-
Mexican financial markets. LTD’s "real business" was not merely
to render investment advice to clients in Mexico, as petitioners
contend. During each of the years in issue, LTD’s income
consisted of four major categories: Management fees, interest
income, currency transactions fees, and other fees and
commissions. LTD’s income, therefore, was derived from
effecting, primarily in the United States, transactions in
financial markets. Accordingly, we conclude that LTD’s "real
business" was providing Mexican nationals with access to non-
Mexican financial markets and that such business was conducted
primarily in the United States.
In Scottish Am. Inv. Co. v. Commissioner, supra at 59, the
Court made "a quantitative and a qualitative analysis of the
services performed". Quantitatively, LTD performed a substantial
number of services in the United States. LTD maintained a client
clearing account at Frost Bank in San Antonio in which it
collected deposits from clients. During the years in issue, LTD
had approximately the following number of client accounts: 257
during 1985, 434 during 1986, 557 during 1987, 870 during 1988,
and 1,131 during 1989. Not all client accounts were actively
traded. Nonetheless, we conclude that the number of LTD’s client
accounts, and, as a corollary, the number of services performed
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