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As we see petitioners' arguments, we think that they fail to
appreciate our reference in our prior opinion to an
"apportionment scheme." In our prior opinion, we held that LTD's
income from currency exchange transactions was characterized as
"compensation for personal services performed both in the United
States and outside the United States and is treated as income
from sources partly within and partly without the United States."
We next stated, "Petitioners, however, did not provide an
apportionment scheme for the currency exchange transactions
income."
By our reference to an "apportionment scheme", we meant to
address petitioners' failure to establish the extent to which
income items were derived either from services performed inside
the United States, on the one hand, or from services performed
outside the United States, on the other hand. Our reference to
an apportionment scheme was not meant to imply that we were
addressing an apportionment of income items between LTD and INC.
By that reference, we meant only that petitioners had not set
forth a methodology for ascertaining whether income items were
derived from inside or outside the United States. Based on our
review of the record, we concluded in our prior opinion that two
checks from LTD's Guadalajara office, representing its
contribution to profits, were income items which "derived
directly from the Guadalajara office's currency operations." The
record, however, does not establish that the remaining currency
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