Inverworld, Inc., et al. - Page 3

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          section 482, and that INC was liable for additions to tax                   
          pursuant to sections 6651, 6653(a), 6656, and 6661.                         
                                  FINDINGS OF FACT                                    
               We incorporate into this Opinion by reference the findings             
          of fact in our prior opinion.  Additionally, we restate below               
          certain of those findings that are relevant to the issues                   
          presented by petitioners' motion for reconsideration.                       
          Furthermore, we set forth below certain supplementary findings of           
          fact that were not set forth in our prior opinion but are,                  
          however, based on the record of the trial of the instant case and           
          relevant to our analysis below.                                             
          Currency Exchange Transactions Income                                       
               LTD engaged in two types of currency exchange transactions.            
                    a.   Currency Swaps                                               
               LTD arranged for its clients currency swaps, which were                
          contracts in dollar futures.  In a currency swap, LTD and a                 
          client entered into a contract in which LTD agreed to sell U.S.             
          dollars to the client for Mexican pesos at some future date.  The           
          sale price for the dollars was determined in accordance with the            
          interest rate negotiated between LTD and the client.  LTD's gross           
          receipts consisted of commissions that it received from Bank of             
          America and United States Trust for arranging the currency swaps.           
          LTD’s direct costs were the commissions it paid out for arranging           
          the currency swaps.  LTD stopped arranging currency swaps on                
          September 1, 1984.                                                          




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