Inverworld, Inc., et al. - Page 188

                                                 - 43 -                                                   
                                     Pace                                 831,176                         
                                     MMA II                               2,903,946                       
                                     Byte                                 116,313                         
                  1The record indicates that, in the direct costs for taxable                             
            year ended June 30, 1985, the interest expenses consisted of IFF                              
            and MMA interest expenses combined without distinction.                                       
                  3.    Currency Exchange Transactions Income                                             
                  LTD engaged in two types of currency exchange transactions.                             
                        a.     Currency Swaps                                                             
                  LTD arranged for its clients currency swaps, which were                                 
            contracts in dollar futures.  In a currency swap, LTD and a                                   
            client entered into a contract in which LTD agreed to sell U.S.                               
            dollars to the client for Mexican pesos at some future date.  The                             
            sale price for the dollars was determined in accordance with the                              
            interest rate negotiated between LTD and the client.  LTD's gross                             
            receipts consisted of commissions that it received from Bank of                               
            America and United States Trust for arranging the currency swaps.                             
            LTD’s direct costs were the commissions it paid out for arranging                             
            the currency swaps.  LTD stopped arranging currency swaps on                                  
            September 1, 1984.                                                                            
                  The gross receipts and direct costs relating to LTD’s                                   
            "Commissions on Foreign Exchange" are as follows:                                             
                        TYE June 30        Gross Receipts    Direct Costs                                 
                        1985               $54,386                  $24,750                               
                        b.     Currency Transactions                                                      
                  The second category of currency exchange transactions that                              
            LTD engaged in was the sale and purchase of dollars on behalf of                              




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