- 10 - FINDINGS OF FACT Many facts have been stipulated and are so found. The stipulations of fact and supplemental stipulations and attached exhibits are incorporated herein by this reference. Petitioners J.J. Zand and Eva Zand3 resided in Naples, Florida, when the petitions were filed in these cases. I. Preliminary Facts A. Background Petitioner was born on June 14, 1923. He became a U.S. citizen in 1953 and remained so during the years at issue. Prior to becoming a U.S. citizen, he was a citizen of Iran. Petitioner moved to Columbus, Ohio, in 1946, where he lived with his family until 1957. Caspian Trading Company of Iran (Caspian Iran) was formed by four of petitioner's classmates in 1945, and owned by the Bakhtiar Brothers, who were not related to petitioner. Its purpose was to import American equipment into Iran and to become an Iranian distributor of U.S. products. From the mid-1950's, petitioner's business in the United States operated under the sole proprietorship name of Caspian Trading Company (CTC), located in Columbus, Ohio. CTC's role was to act as a liaison between Caspian Iran and certain 3 While Eva Zand is a petitioner for the years 1978 through 1981 because she filed joint returns with J.J. Zand, most of the adjustments at issue involve the activities of J.J. Zand, who is referred to throughout our findings of fact and opinion as petitioner.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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