Inverworld, Inc., et al. - Page 25

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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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