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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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