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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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