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business activities. Rather, WHIP served as a shell corporation
and was not an operating company.
In 1978, at petitioner's direction, Mr. Dutton, then an
employee of Caspian Development Company (CDC), withdrew $610,000
from the WHIP account at Barclays Bank Bahamas. Mr. Dutton then
deposited these funds to petitioner's CNB account in Columbus,
Ohio.
Petitioner signed an agreement in July 1970 with Occidental
Petroleum under which payments were to be made to WHIP.
Petitioner directed all payments into the WHIP Barclays Bank
Bahamas account; he was the sole person who withdrew funds from
the account; and he unilaterally took the funds from the account
and deposited them to this own account in Columbus, Ohio.
Therefore, the interest on the Barclays Bank Bahamas account for
the WHIP shell entity of $25,025 in 1974, $29,338.94 in 1975, and
$16,998.06 in 1976 was earned and controlled by petitioner.
V. Character of Gain on Disposition of Diesel Power Stock
Petitioner acquired all of Diesel Power's stock from his
father and Mr. Taleghani in 1958. He paid nothing for it.
In December 1977 petitioner sold all of the stock he then
owned in Diesel Power to Mr. and Mrs. Khalatbari. Under the sale
agreement, he was to be paid $3,300,000 on December 21, 1977,
$625,000 on March 1, 1978, $700,000 on or before December 15,
1978, and $265,000 on or before December 3, 1979. The total cash
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