J.J. Zand - Page 14

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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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