Inverworld, Inc., et al. - Page 227

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            over the continuous period of time in issue.  INC’s authority to                              
            purchase certificates of deposit and term deposits was not                                    
            "limited only to unusual cases", and its authority was not                                    
            "separately secured" by INC from LTD "with respect to each                                    
            transaction effected."  The exercise of INC’s authority was not                               
            merely occasional or infrequent.  Accordingly, we conclude that                               
            INC exercised its authority to negotiate and to conclude                                      
            contracts with the regularity and continuity required by section                              
            1.864-7(d)(i)(ii), Income Tax Regs.  Consequently, we hold that                               
            INC is a dependent agent who had "the authority to negotiate and                              
            conclude contracts" in the name of the foreign corporation LTD                                
            and "regularly" exercised such authority within the meaning of                                
            section 1.864-7(d)(1)(i), Income Tax Regs.                                                    
                  As INC is a dependent agent which had "the authority to                                 
            negotiate and conclude contracts" in the name of LTD and                                      
            "regularly" exercised such authority over a continuous period of                              
            time, INC’s office will not be disregarded in determining whether                             
            LTD had an office or other fixed place of business within the                                 
            meaning of section 1.864-7(d), Income Tax Regs.  Sec. 1.864-                                  
            7(d)(3)(i), Income Tax Regs.  Accordingly, we conclude that INC’s                             
            office is to be used in deciding whether LTD had "an office or                                
            other fixed place of business in the United States" within the                                
            meaning of section 1.864-7(d), Income Tax Regs.                                               
                 As INC is a corporation, and respondent makes no argument                               
            that its separate existence should be ignored, and as LTD had no                              




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