- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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