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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of fact and the exhibits thereto are
incorporated herein.
The Cleveland Trencher Co. (petitioner) is an Ohio
corporation whose principal place of business was in Cleveland
when the petition was filed. Petitioner is an accrual basis
taxpayer.
Petitioner, established in 1904, is in the business of
manufacturing and selling trenching machines (also called
ditching machines or trenchers). Trenchers are tractorlike
machines used to dig ditches for pipelines, irrigation channels,
and other purposes.
A corporation called A-A-H International Trading Co., Inc.,
was incorporated in Ohio in 1984 "To operate an export, import
business and any lawful act or activity for which corporations
may be formed under * * * Ohio" law. Its corporate charter was
revoked in 1985.
On October 13, 1986, petitioner entered into an agreement
(the first commission agreement) with "AA&H International"
(AA&H); the agreement was executed on behalf of AA&H by Metin
Aydin (Mr. Aydin). On March 2, 1987, petitioner entered into
another agreement (the second commission agreement) with AA&H and
Mr. Aydin. The second commission agreement called for payments
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