- 23 - length standard. After considering petitioners' arguments, we do not reconsider our holdings with respect to the section 482 allocations of income to INC. 2. Currency Exchange Transactions Income As to the currency exchange transactions income, petitioners seek reconsideration of the section 482 allocations of LTD's gross receipts to INC. Petitioners contend that INC's contribution to the earning of currency exchange revenues was ministerial at best, as evidenced by the fact that the income was not a "fee" but rather a "spread". Additionally, petitioners argue that LTD's promoter in Mexico negotiated the exchange rate with his client, structured the exchange using a Mexican exchange house, and calculated and tracked LTD's spread, and, therefore, there is no basis in the record for our holding that "LTD paid INC to effect currency transactions". Petitioners argue that allocating the gross receipts overstates the value of INC's services to LTD and its promoters in Mexico and gives no credit to the role and contribution of the promoters. Accordingly, petitioners argue that the allocation should be based on a charge in the nature of a fixed, wire transfer fee that would normally be charged in carrying out the services INC "might be called upon to perform." We do not agree. In our prior opinion, we found that clients paid LTD to arrange four types of currency transactions. We are satisfied that the record establishes that the currency transactions werePage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
Last modified: May 25, 2011