Inverworld, Inc., et al. - Page 237

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            activities was the San Antonio office.  Consequently, we conclude                             
            that Piedras Negras does not support petitioners’ position in the                             
            instant case.                                                                                 
                  In Abegg, the taxpayer engaged in activities that were not                              
            as substantial in both quantity and quality as LTD’s activities                               
            in the instant case.  In Abegg, the taxpayer engaged in                                       
            activities solely for its own benefit (viz, collecting dividends                              
            and interest, managing existing investments, and investigating                                
            new investments).  Abegg v. Commissioner, supra at 153-154.  In                               
            contrast, in the instant case, LTD had clients to whom it                                     
            provided services and marketed investment products.                                           
            Additionally, in Abegg, the taxpayer had operations in the United                             
            States that we characterized as "planning activities", id. at                                 
            154, in contrast to LTD’s operations in the instant case, where                               
            LTD’s U.S. operations dealt with third parties and therefore                                  
            consisted of more than mere "planning activities".  Consequently,                             
            we conclude that Abegg is not dispositive of the instant case.                                
                  In Amalgamated Dental, the Court held that the taxpayer was                             
            not "engaged in trade or business within the United States"                                   
            because the relationship between the parties was that of                                      
            vendor/vendee.  Amalgamated Dental Co. v. Commissioner, supra at                              
            1015-1016.  We conclude that the facts in the instant case are                                
            distinguishable from those in Amalgamated Dental.  The                                        
            relationship between LTD and INC was not that of vendor/vendee.                               
            LTD delegated authority to INC, which, inter alia, purchased                                  




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