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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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