- 168 - 864(b) during the taxable years in issue. We examine separately the activities of LTD’s trade or business relating to each of the commissions and fees. For the following reasons, we hold that in each of the following commission or fee income categories, the associated activities of LTD’s trade or business were a material factor in the realization of such commission or fee: Currency Fund: LTD accepted clients’ deposits, opened an account with a foreign bank, and issued periodic statements to clients. FEIM Fund: LTD accepted clients’ deposits, transferred such deposits to Merrill Lynch, and issued periodic statements to clients. Matric Fund: LTD handled the paperwork and general administration and distributed the interest payments to the investors. Inversat Fund: LTD accepted clients' deposits, transferred the funds from Inversat Fund to Inversat REIT, and provided general investment management. TVA administration fee: LTD instructed INC to pay TVA a monthly stipend to cover its development expenses and administered the funds raised in the capital call itself. Client incorporation and trust creation and legal advice income: LTD counseled clients regarding the proper entity for their investments and handled the paperwork, including arranging legal services from third parties.Page: Previous 158 159 160 161 162 163 164 165 166 167 168 169 170 171 172 173 174 175 176 177 Next
Last modified: May 25, 2011