Inverworld, Inc., et al. - Page 23

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          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 were             




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