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manufacturers with which petitioner had a business relationship.
During this period petitioner had an arrangement with Caspian
Iran whereby he operated in Columbus, Ohio, what he referred to
in his dealings with manufacturers as a U.S. "branch office" of
Caspian Iran. Petitioner, through CTC, sought to act as a
distributor on behalf of American manufacturers whose goods were
then sold in Iran by Caspian Iran. The earnings of both Caspian
Iran and petitioner were on a commission basis. There was an
understanding between petitioner and Caspian Iran that all
commissions earned would be split 60 percent for Caspian Iran and
40 percent for petitioner.
Petitioner moved back to Iran from Columbus, Ohio, at the
end of 1957. His connections with Caspian Iran were severed in
approximately October 1957. In an agreement terminating the
relationship, Caspian Iran and CTC agreed that commissions earned
in pending transactions would be divided 60 percent for Caspian
Iran and 40 percent for CTC.
In 1958, Diesel Power Trading Company (Diesel Power) was
established in Iran by petitioner, his father, Jamil Z. Irani,
and Mr. Taleghani, a former classmate of petitioner. Petitioner
subsequently acquired the Diesel Power stock of his father and
Mr. Taleghani, and he owned 100 percent of Diesel Power from the
late 1950's or early 1960's until the end of 1974. During the
early period of Diesel Power's existence, petitioner's father was
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