- 103 - 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 cashPage: Previous 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 Next
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