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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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