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to be examined in deciding the source of the commission income.
LTD provided many services beyond the initial sale of the fund.
We conclude that LTD’s commission was compensation for providing
those services, not for selling the fund. In sum, LTD’s
management of the FEIM Fund entailed performing personal services
in San Antonio. Accordingly, we hold that LTD's FEIM Fund
commission 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).
We similarly conclude that LTD’s Matric Fund commission,
initiation fee, and consulting fee are compensation for
investment services. The services that LTD rendered in relation
to the Matric Fund included handling the paperwork and general
administration, and administering the interest payments to the
investors. Clients placed their commitments with LTD through the
San Antonio office. LTD handled all paperwork regarding the
Matric Fund accrual of interest in the San Antonio office. We
disagree with petitioners’ contention that only the selling of
the fund is to be examined in deciding the source of the
commission income. LTD provided many services beyond the initial
sale of the fund. We conclude that LTD’s commission was
compensation for providing such services, not for selling the
fund. In sum, LTD’s management of the Matric Fund entailed
performing personal services in San Antonio. Accordingly, we
hold that LTD's Matric Fund income is characterized as
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