J.J. Zand - Page 10

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                                   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.                                 




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