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connection with the C-130 aircraft were made on December 7, 1972,
May 1, 1973, June 8, 1973, and January 16, 1974. Each of these
three amendments was signed by petitioner on behalf of himself
and Sunvaco.
Mr. Zanganeh was involved in Sunvaco transactions in some
respect. A 1972 letter from Lockheed to Mr. Zanganeh discusses
the terms and conditions contained in the agreement with Sunvaco
in connection with the TriStar Model L-1011 aircraft purchased by
Iran National Airlines. The letter asks Mr. Zanganeh to confirm
these terms on behalf of Sunvaco. Another version of the same
letter addressed to Mr. Zanganeh worded somewhat differently
affirmed, "Pursuant to Mr. J. J. Zand's request", Lockheed's
understanding of the fee arrangement with Sunvaco. The record
contains what appears to be a draft of a response by petitioner
to Lockheed's letter. Mr. Zanganeh was paid $80,000 out of the
WHIP account in 1972 and $75,000 out of a CTC account in 1974.
Petitioner reimbursed himself for the CTC payment by writing a
check to himself on the Diesel Power Bank of America account.
In addition to these payments to Mr. Zanganeh, petitioner
and his employees instructed Lockheed how to allocate and where
to mail commission payments required under the Lockheed
contracts. In 1971 petitioner also instructed Price Waterhouse
to transfer to an account in Switzerland $1,000,000 of the total
amount of $1,229,700 expected to be received by WHIP from
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