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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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