Inverworld, Inc., et al. - Page 28

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                        c.     Interest Income                                                            
                               (1) Loans                                                                  
                  Petitioners do not address either the character or the                                  
            source of the income earned by LTD on its loans to clients and                                
            Mexican corporations.                                                                         
                  Respondent contends that the character of the income from                               
            LTD's loans is interest income.  Respondent argues that the                                   
            income is attributable to interest on loans made to LTD's clients                             
            and Mexican corporations.  Because the debtors resided without                                
            the United States, respondent contends that the interest is                                   
            treated as income from sources without the United States.                                     
                  We believe that LTD’s interest from loans was all paid by                               
            Mexican individuals and corporations.  Accordingly, we hold that                              
            the interest is characterized as interest from non-U.S. obligors                              
            and is treated as income from sources without the United States.                              
            Sec. 862(a)(1).                                                                               
                               (2) MMA II                                                                 
                  Petitioners contend that LTD’s MMA II income was interest                               
            earned on client funds placed in non-U.S. bank deposits, thus                                 
            constituting income from sources without the United States.                                   
            Respondent agrees that the MMA II income was interest.                                        
            Respondent, however, argues that petitioners have failed to prove                             
            that the interest came from a foreign source.                                                 
                  We find that, in the MMA II program, clients placed funds                               
            with LTD and earned interest on such funds.  Mexican corporations                             




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