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INVERWORLD, INC. v. COMMISSIONER

Docket Nos. 27089-90, 27090-90, 3441-93, 3442-93, 3443-93, 3444-93.

73 T.C.M. 2777 (1997)

T.C. Memo. 1997-226

InverWorld, Inc., et al. v. Commissioner.

United States Tax Court.

Filed May 12, 1997.

Attorney(s) appearing for the Case

Turner P. Smith, New York, N.Y., Nancy E. Delaney, and Robert D. Whoriskey, for the petitioner in Docket No. 27089-90. Turner P. Smith, Nancy E. Delaney, T. Barry Kingham, and Robert D. Whoriskey, for the petitioner in Docket No. 27090-90. Turner P. Smith and Nancy E. Delaney, for the petitioners in Docket Nos. 3441-93, 3442-93, 3443-93, and 3444-93. Jill Frisch, Peter J. Graziano, and Maria Stabile, for the respondent.

SUPPLEMENTAL MEMORANDUM FINDINGS OF FACT AND OPINION

WELLS, Judge:

These cases are before us on petitioners' motion pursuant to Rule 1612 for reconsideration of our prior Memorandum Opinion, [Dec. 51,428(M)] T.C. Memo. 1996-301 (prior opinion). In our prior opinion, as to InverWorld, Ltd. (LTD), we held, inter alia, that LTD was engaged in trade or business within the United States pursuant...

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