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submitted as joint exhibits workpapers produced by Deloitte in
its audit of LTD and INC, including analysis files, general
files, permanent files, tax service files, Auditors' Reports,
Report Records, draft and Report Copies of Consolidated Financial
Statements, and supporting documents.
In our prior opinion, our findings of fact regarding the
currency transactions were based upon the Deloitte workpapers,
which contained a description of four types of currency
transactions. The Deloitte workpapers were offered and entered
into evidence at trial without any objection by petitioners.
Consequently, we are satisfied that the record in the instant
case supports our finding that LTD engaged in the four types of
currency transactions described.
Petitioners further request that we reconsider our holding
that, because petitioners did not provide an "apportionment
scheme" for the currency exchange transactions income, all of
LTD's income from currency transactions constitutes income from
sources within the United States. Petitioners contend that none
of LTD's receipts from currency transactions should be deemed
income from sources within the United States because the weight
of the evidence established that INC had only the most marginal
ministerial involvement in any aspect of the currency
transactions. Accordingly, petitioners argue that there is no
need to apportion between INC's role and that of LTD's because
INC's role is immaterial.
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Last modified: May 25, 2011