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seeking verification that certain payments had been made and had
not been improperly used. One of the payments listed in this
letter was a "Payment to account of Interrep, S.A. for the group
represented by Mr. James Zand". Petitioner testified that he
signed the letter at the airport when he was in a hurry, read the
affirmation at the end of the letter, and did not read the rest
of the letter. He also indicated that he did not recall
receiving any money from Interrep; there is no evidence to the
contrary. We conclude that the record does not contain adequate
evidence that petitioner was sufficiently related to Interrep
that he should be taxed on its income.
With regard to the Ashland's commission payments to All
Patents in 1974 and 1975, we conclude that, although the Ashland
consultancy agreement was in All Patents' name, not petitioner's,
it was for the "personal services" of petitioner. Ashland
representatives testified at trial that they were under the
impression they had hired petitioner to act as an intermediary
between Ashland and NIOC. Furthermore, Ashland understood that
petitioner owned All Patents, at least in part, although there is
no concrete evidence to that effect in the record. While
petitioner testified that he understood Ashland's payments to All
Patents were for the benefit of NIOC, there is no indication that
Ashland intended to receive services from Dr. Fallah or any other
NIOC representative under the consultancy agreement.
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