- 10 - 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 currencyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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