J.J. Zand - Page 81

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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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