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highly involved in its operation. His father was Diesel Power's
managing director until the mid-1960's, and the commercial
license of Diesel Power at one time was issued in his name. Such
license may only be issued to a resident of Iran.
Sometime between 1958 and 1961, petitioner moved his family
to nearby Beirut, Lebanon. While in Teheran and Beirut,
petitioner worked on Diesel Power matters using either the
Caspian Iran or CTC name.
Petitioner also maintained an office in Columbus, Ohio,
during these years with at least one employee. Regular
communications from Diesel Power were received and passed on to
various American manufacturers via the Columbus, Ohio, office;
that office also expedited shipment and collected commissions
earned. Petitioner returned to the United States in 1961.
B. Ownership of Diesel Power
Farshid Khalatbari (Mr. Khalatbari) joined Diesel Power in
the mid-1960's and replaced petitioner's father as the managing
director. Mr. Khalatbari married Diana Zand, petitioner's
sister, who was then referred to as Diana Khalatbari. In 1971 a
dispute arose between petitioner and Mr. Khalatbari;
consequently, Mr. Khalatbari left Diesel Power for about 10 days.
He agreed to return upon assurances from petitioner that he would
become a part owner of Diesel Power. It was not until November
1974, that Diesel Power, which formerly had been a limited
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