Inverworld, Inc., et al. - Page 145

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            amount of the investment.  LTD also charged an annual management                              
            fee, starting with the second year, of 1.00 percent of the value                              
            of the assets under management.  Petitioners did not present                                  
            evidence on and the record does not reveal the precise amounts of                             
            clients’ funds at each level of the graduated placement costs.                                
            Consequently, we are unable to calculate LTD’s Inversat Fund                                  
            commission on a sliding scale.  We note that Deloitte used in its                             
            audit a figure of 3.00 percent, and we apply that amount in the                               
            instant case.  Accordingly, the arm’s length charge for INC’s                                 
            services for such operation is the amount of clients’ newly                                   
            placed net assets times 3.00 percent plus the amount of clients’                              
            already placed net assets times 1.00 percent.                                                 
                  LTD paid INC to maintain investments placed in the Matric                               
            Fund.  LTD charged its client, Matric Corp., a consulting fee of                              
            $47,500 to maintain the Matric Fund.  Accordingly, the arm’s                                  
            length charge for INC’s services for that operation is $47,500.                               
                  LTD paid INC to maintain investments placed in TVA.  LTD                                
            charged its client, TVA, Inc., an administration fee of $5,000                                
            per month.  Accordingly, the arm’s length charge for INC’s                                    
            services for that operation is $5,000 per month.                                              
                  LTD paid INC to effect currency transactions.  The amount                               
            that LTD earned is the amount that LTD charged its clients.  Some                             
            of LTD’s income, however, was generated by LTD’s Guadalajara                                  
            office and not by INC.  Consequently, INC will not be allocated                               
            that income.  Accordingly, the arm’s length charge for INC’s                                  





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