Inverworld, Inc., et al. - Page 238

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            certificates of deposit in LTD’s name.  Accordingly, we conclude                              
            that Amalgamated Dental is not dispositive of the instant case.                               
                  Petitioners also rely heavily on Spermacet Whaling &                                    
            Shipping Co. S/A v. Commissioner, 30 T.C. 618 (1958).  In                                     
            Spermacet, this Court addressed the issue of whether the taxpayer                             
            was "engaged in trade or business within the United States"                                   
            within the meaning of section 231(b) of the 1939 Code, as                                     
            amended.  The taxpayer entered into a contract to provide                                     
            management services for whaling boats.  The Court held that the                               
            "business in which * * * [the taxpayer] was engaged was that of                               
            managing the [whaling] expedition" and that the taxpayer’s                                    
            "activities which produced the income in question took place                                  
            almost entirely on the high seas or in Norway."  Id. at 633.                                  
            Additionally, the Court held that the activities that the                                     
            taxpayer performed within the United States were "without                                     
            substance."  Id.  The Court stated:                                                           
                  * * * [the actions in the United States of the                                          
                  taxpayer’s forty percent shareholder] in receiving                                      
                  monthly statements or correspondence involving * * *                                    
                  [the taxpayer], or in paying a limited number of                                        
                  obligations requiring payment in American dollars out                                   
                  of a bank account * * * maintained by * * * [the                                        
                  taxpayer], were ministerial and clerical in nature,                                     
                  involving very little exercise of discretion or                                         
                  business judgment necessary to the production of the                                    
                  income in question.  * * *  [Id. at 633-634.]                                           
            Finally, "The holding of the directors’ meetings in New York City                             
            solely for the personal convenience of the directors was of no                                
            particular consequence."  Id. at 634.  Accordingly, the Court                                 





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