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TYE June 30 Gross Receipts Direct Costs
1986 $147,951 $18,286
1987 363,014 126,855
1988 290,518 161,037
1989 404,286 227,697
OPINION
A. Currency Exchange Transactions Income
In our prior opinion, we found that LTD engaged in two types
of currency exchange transactions: currency swaps, which were
contracts in dollar futures, and currency transactions, which
included the sale and purchase of U.S. dollars on behalf of
clients. We found that LTD engaged in four types of currency
transactions.
Petitioners request that we reconsider our findings that LTD
engaged in currency transaction types (ii) through (iv).
Petitioners argue that the evidence at trial shows that there was
in fact only one type of currency transaction (type (i)).
Petitioners state that they do not believe there is testimony or
documents to suggest that any of the transaction types (ii)
through (iv) occurred and therefore request that such
transactions be stricken from our findings of fact.
We found in our prior opinion that, during 1984, LTD and INC
engaged the services of the accounting firm of Deloitte Haskins &
Sells (Deloitte), which performed a separate audit of each
company and a consolidated audit of LTD and subsidiaries for each
taxable year ended June 30, 1984 through 1989. The parties
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