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is engaged in "trade or business within the United States" is
whether substantial profit-oriented activities regularly and
continuously occur in the United States whether carried on
directly by the taxpayer or through agents.
Petitioners rely on a line of cases holding that the mere
maintenance of records and collection of rents, interest, or
dividends through managerial attention to securities does not
constitute trade or business. See, e.g., Higgins v.
Commissioner, 312 U.S. 212, 218 (1941); Continental Trading, Inc.
v. Commissioner, 265 F.2d 40 (9th Cir. 1959); DeKrause v.
Commissioner, T.C. Memo. 1974-291. The taxpayer in each of those
cases managed only personal investments and/or personal
investment income. Because those cases did not address taxpayers
who managed the investments of others, as did LTD, we conclude
that they are not dispositive of the instant case.
Petitioners also cite several cases which are
distinguishable on their facts, to wit: Piedras Negras
Broadcasting Co. v. Commissioner, 127 F.2d 260 (5th Cir. 1942),
affg. 43 B.T.A. 297 (1941); Abegg v. Commissioner, 50 T.C. 145
(1968), affd. 429 F.2d 1209 (2d Cir. 1970), and Amalgamated
Dental Co. v. Commissioner, 6 T.C. 1009 (1946). In Piedras
Negras, the court held that none of the taxpayer’s income was
derived from sources within the United States. Piedras Negras
Broadcasting Co. v. Commissioner, supra at 261. In the instant
case, we conclude that the main situs of LTD’s income-producing
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