Inverworld, Inc., et al. - Page 9

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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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