Inverworld, Inc., et al. - Page 27

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            of certificates of deposit issued by foreign branches of Mexican                              
            banks and that the character of the Pace investments income is                                
            therefore interest income.  Petitioners contend that the Pace                                 
            investments income is from sources without the United States                                  
            because the obligors were foreign.                                                            
                  Respondent does not specifically address either the                                     
            character or the source of the Pace investments income.                                       
            Respondent merely argues that petitioners have failed to prove                                
            that the income is from a foreign source.                                                     
                  Petitioners' contention that the Pace investments were                                  
            merely purchases of certificates of deposit issued by foreign                                 
            branches of Mexican banks is unsupported by the record.  We                                   
            believe that the Pace investments constituted a specialized                                   
            mechanism for clients to draw upon their unused lines of credit.                              
            The income that LTD earned from its Pace investments was the                                  
            excess of (1) the sum of the interest earned from the Mexican                                 
            banks and the fees earned from the clients, over (2) the interest                             
            paid to the clients as their stated rate of return.  We conclude                              
            that such income represented compensation for services rendered                               
            in San Antonio in arranging the Pace investments.  Accordingly,                               
            we hold that the Pace investments income is characterized as                                  
            compensation for personal services performed in the United States                             
            and is treated as income from sources within the United States.                               
            Sec. 861(a)(3).                                                                               






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