Inverworld, Inc., et al. - Page 30

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          the taxable years in issue.  As discussed in our prior opinion,             
          LTD earned income by retaining the difference between the                   
          interest that it obtained on client investments and the interest            
          that it credited to client accounts,12 which we characterized as            
          compensation for services.  LTD received such service income in             
          addition to the management fee or commission that it charged its            
          clients for a particular investment.  In sum, we do not                     
          reconsider any of the section 482 allocations of income to INC,             
          which, as to LTD, take the form of additional compensation                  
          expenses.                                                                   
          E.   Section 482 Correlative Adjustments                                    
               Petitioners' motion requests that we reconsider our holding            
          in our prior opinion that LTD is not entitled to a correlative              
          adjustment, pursuant to section 1.482-1(d)(2), Income Tax                   
          Regs.,13 once a primary adjustment is made to INC's income.                 

          12   As we found in our prior opinion, during 1986, the                     
          discretionary authorization signed by each LTD client was changed           
          to include the provision that                                               
               The rate of return credited to the Client's account may                
               not reflect directly the rate of return earned by                      
               specific investments; the Client's rate of return may                  
               be net of expenses or may reflect the fact that * * *                  
               [LTD] may retain the benefit of special rates                          
               attributable to the volume of investments controlled by                
               * * * [LTD].                                                           
          13   Section 1.482-1(d)(2), Income Tax Regs., provides:                     
                    Whenever the district director makes adjustments                  
               to the income of one member of a group of controlled                   
               taxpayers (such adjustments being referred to in this                  
                                                             (continued...)           




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