Inverworld, Inc., et al. - Page 239

                                                 - 94 -                                                   
            stated that "we are convinced that * * * [the taxpayer] was not                               
            engaged in any substantial, regular, or continuous ordinary                                   
            business activity in the United States."  Id. at 634.                                         
                  We conclude that the facts in the instant case are                                      
            distinguishable from those in Spermacet.  LTD's activities in the                             
            United States, as conducted by LTD directly and through INC,                                  
            exceeded the mere receipt of LTD’s own monthly statements or                                  
            correspondence and limited payments of bills from a bank account.                             
            LTD received clients’ funds and placed such funds with third                                  
            parties.  Additionally, LTD’s activities in the United States                                 
            were more extensive than the taxpayer’s "ministerial and                                      
            clerical" activities in Spermacet.  LTD traded in stocks or                                   
            securities in the United States.  A substantial part of the                                   
            activities that produced LTD’s income took place in San Antonio.                              
            In sum, we conclude that Spermacet Whaling & Shipping Co. S/A v.                              
            Commissioner, supra, is not dispositive of the instant case.                                  
                  We also conclude that petitioner’s reliance on Scottish Am.                             
            Inv. Co., Ltd. v. Commissioner, 12 T.C. 49 (1949), is without                                 
            merit.  In Scottish American, this Court addressed the issue of                               
            whether a group of Scottish trusts, by virtue of the activities                               
            of an office in the United States, were "engaged in trade or                                  
            business within the United States" within the meaning of section                              
            231(b) of the 1939 Code, as amended.  The Court found the                                     
            following facts:                                                                              






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