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services to LTD relating to currency exchange transactions,
including, inter alia, contacting Bank of America and United
States Trust to obtain exchange rates and to arrange the currency
swaps, depositing or withdrawing dollars or pesos, and
maintaining records of LTD's and its clients' positions with
respect to the currency transactions. 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; i.e., the taxable income that would have
resulted to INC in an arm's-length transaction. See Altama Delta
Corp. v. Commissioner, supra; Seagate Tech., Inc. & Consol. Subs.
v. Commissioner, supra; Sundstrand Corp. & Subs. v. Commissioner,
supra.
Petitioners argue that we should "deduct" from the section
482 allocations we made in our prior opinion the income earned
from services performed by the promoters in currency transaction
type (i), in which LTD arranged sales of dollars to a client in
exchange for pesos. As stated above, petitioners argue that an
allocation of the gross receipts to INC gives no credit to the
role and contribution of the promoters. Petitioners suggest a
basis for apportionment in which INC is allocated only 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." As stated above, we disagree with the premise of
petitioners' argument that LTD performed only one type of
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