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directly to Diesel Power that were not reported as income by
petitioner and which respondent did not allocate to petitioner as
income in the deficiency notices. In other words, respondent
appears to concede that Diesel Power did actually earn a
considerable amount of commissions in its own right. The areas
of contention mostly involve commissions that were paid to CTC, a
portion of which were then attributed to Diesel Power on the CTC
receipts journal, as well as certain commissions that were issued
in the name of Diesel Power that were allegedly earned by CTC or
petitioner, but were not reflected on the CTC receipts journal.
Third, petitioner contends that he relinquished his
controlling interest in Diesel Power in 1971 or 1974. He
testified that in 1971 he and Mr. Khalatbari had a dispute
because Mr. Khalatbari wanted to be a Diesel Power shareholder
and that, as a result of this dispute, Mr. Khalatbari left Diesel
Power for a few days. Petitioner then indicated that, when Mr.
Khalatbari returned, petitioner agreed to transfer 60 percent of
his interest in Diesel Power to Mr. and Mrs. Khalatbari. This
agreement was allegedly not "formalized" until 1974. The record
shows that petitioner received 11,750,000 rials for the transfer
of his 60-percent interest. When petitioner transferred the
remainder of his stock to the Khalatbaris in 1977, there is no
disagreement that there was a payment of money. We conclude that
there was in fact a reduction of petitioner's ownership in Diesel
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