Inverworld, Inc., et al. - Page 14

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          or business were "a material factor in the realization of the               
          income" within the meaning of section 864(c)(2)(B).                         
          Consequently, we do not reconsider our holding that LTD's U.S.              
          source currency exchange transactions income is effectively                 
          connected income pursuant to section 1.864-4(c)(5)(vi)(b), Income           
          Tax Regs., and section 864(c)(2)(B).                                        
          B.   Client Incorporation and Trust Creation Fees                           
               Petitioners request that we reconsider our finding in our              
          prior opinion regarding the client incorporation fees that "the             
          incorporation package completed by the lawyers or fiduciaries was           
          then returned to INC, which returned the package to the client in           
          Mexico."  Petitioners contend that the incorporation packages               
          were returned not to the client in Mexico but rather to the                 
          promoters, who then dealt directly with their clients.  Our                 
          finding was based upon petitioners' proposed finding in their               
          opening brief, which was supported by the record.  The proposed             
          finding states:  "The incorporation package, completed by these             
          lawyers and fiduciaries, was then returned to San Antonio.  From            
          there, it was forwarded back to the client in Mexico."                      
          Petitioners' proposed finding of fact makes no mention of                   
          promoters in the process of sending the incorporation package               
          from INC to the client in Mexico.  Accordingly, we do not                   
          reconsider such finding.                                                    
               Additionally, petitioners request that we reconsider our               
          holding that LTD's income from client incorporation and trust               




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