Inverworld, Inc., et al. - Page 10

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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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