Inverworld, Inc., et al. - Page 86

                                                - 169 -                                                   
                  Letters of credit:  LTD sent the letters of credit, either                              
            directly or indirectly through a bank, to Mexican banks in order                              
            to secure loans for clients.                                                                  
                  Foreign exchange investments:  LTD contacted institutions                               
            for exchange rates and deposited or withdrew dollars or pesos per                             
            the client's direction.                                                                       
                  Treasury bills:  LTD arranged for the purchase of Treasury                              
            bills through Merrill Lynch and other third party institutions.                               
                  Wires and checks:  LTD effected the wire and check                                      
            transactions.                                                                                 
                  Gold and silver futures:  LTD obtained rates and helped                                 
            effect the exchange transactions of gold and silver.                                          
                  Project income:  LTD helped arrange the research project and                            
            derived the income therefrom.                                                                 
                  Income from investments, other commissions income, other                                
            commissions and fees, and other income:  LTD performed the                                    
            services that earned LTD the income in such categories.                                       
                  We conclude that, for each commission or fee, excepting the                             
            two types of foreign source TVA commissions, the activities of                                
            LTD’s trade or business were "a material factor in the                                        
            realization of the income" within the meaning of section                                      
            864(c)(2)(B).  We have given due regard to the question of                                    
            whether such income was accounted for through such trade or                                   
            business, and we find LTD's commissions and fees to have been                                 
            accounted for through LTD's trade or business.  Sec. 864(c)(2).                               




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