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actually performed, sometimes in combination, by LTD, INC, the
Guadalajara office, and the promoters. As respondent determined
that income should be allocated to INC pursuant to section 482,
INC's true taxable income from its performance of such services
must be ascertained. The record, however, does not establish
that clients made payments to each entity performing a service in
the currency transaction; in other words, clients did not pay a
separate fee to LTD, INC, the Guadalajara office, and the
promoters.
Nonetheless, in our prior opinion, based upon information
provided in the Deloitte workpapers, we excluded from the section
482 allocations the income earned from services performed by the
Guadalajara office. We, however, did not exclude from the
section 482 allocations any income earned from services performed
by the promoters because petitioners did not provide any basis
for apportioning such income. Additionally, the record did not
provide sufficient information to establish a basis for
apportionment on our own.
We disagree with the premise of petitioners' argument that
LTD performed only one type of currency transaction for its
clients. As discussed supra and in our prior opinion, LTD
performed four types of currency transactions. Additionally, we
find to be without merit petitioners' argument that INC's
services were "ministerial". Notwithstanding petitioners'
characterization of INC's services, INC did in fact render
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