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for personal services performed outside the United States and is
treated as income from sources without the United States. Sec.
862(a)(3).
(4) Client Incorporation and Trust
Creation, Legal Advice
Income, and Letters of Credit
Respondent contends that the character of the client
incorporation and trust creation fees, the legal advice income,
and the letters of credit fees are personal services income.
Respondent contends that such income items should be treated as
income from sources within the United States because the
investment services relating to the income were provided in San
Antonio.
Petitioners do not dispute respondent’s contentions.
Consequently, we treat petitioners as having conceded that such
income is characterized as compensation for personal services
income performed in the United States and is treated as income
from sources within the United States. Sec. 861(a)(3).
(5) Foreign Exchange Investments
We analyze LTD’s foreign exchange investments income in a
manner similar to that in the currency exchange transactions
section, supra pp. 110-112.
Petitioners, however, did not provide any basis for
apportionment of the foreign exchange investments income.
Accordingly, we sustain respondent's determinations that such
income is characterized as compensation for personal services
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