- 7 -
paid under the terms of the oral agreement with respect to
petitioner's services.
In an attempt to secure large amounts of crude oil for
Ashland, petitioner and Dr. Young traveled many times to Cameroon
(at the instruction of Ashland), and they met with officials of
Cameroon's national oil company, Soci�t� Nationale des
Hydrocarbures (SNH). In March 1980, Ashland and Cameroon agreed
that Ashland would acquire oil from SNH through Ashland's Bermuda
subsidiary, Ashland (Bermuda) Limited (ABL).
At or about the same time, petitioner and Dr. Young decided
that they wanted to organize a corporation in Bermuda or some
other traditional tax haven to avoid Federal income tax on their
commissions from Ashland. They contacted the law firm of
Danzansky, Dickey, Tydings, Quint & Gordon (which was merged into
Finley, Kumble, Wagner, Heine, Underberg & Casey on or about
January 1, 1981, and which with its successor will hereinafter be
referred to as Finley Kumble),6 to obtain assistance in
organizing such a corporation. Following discussions with
petitioner and Dr. Young, Finley Kumble understood that
6 Although Danzansky, Dickey, Tydings, Quint & Gordon is a
different firm than Finley, Kumble, Wagner, Heine, Underberg
& Casey, the attorneys at these firms who advised petitioner and
Dr. Young were generally the same throughout the relevant period
herein. Robert B. Washington, Jr., one of the principal partners
in charge of the accounts of petitioner, Dr. Young, and the
related entities throughout the relevant time, oversaw and was
actively involved in most (if not all) of the advice that the
firms rendered to petitioner and Dr. Young, either personally or
on behalf of their related entities.
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