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from sources outside the United States, Rule 142(a), and have not
met that burden. Accordingly, we do not reconsider our holding
that LTD's income from client incorporation and trust creation is
to be treated as income from sources within the United States.
C. Pace Investments Income
In our prior opinion, we found that LTD's Pace investments
constituted a specialized mechanism for clients to draw upon
their unused lines of credit with Mexican financial institutions.
In their motion, however, petitioners ask the Court to reconsider
our finding and to adopt instead petitioners' proposed finding of
fact that "the Pace investment involved merely the purchase of
certificates of deposit issued by the foreign branches of Mexican
banks".
In our prior opinion, our findings regarding the Pace
investments were based upon the Deloitte workpapers, which
contained a description of the handling of the Pace investments.
As we stated, supra, the Deloitte workpapers were offered and
entered into evidence at trial without any objection by
petitioners. We are satisfied that the record in the instant
case establishes that the Pace investments constituted a
specialized mechanism for clients to draw upon their unused lines
of credit with Mexican financial institutions. Accordingly, we
do not reconsider such finding.
Additionally, petitioners argue that, because the Pace
investments interest derived from Mexican banks, the interest
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