- 171 - 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.Page: Previous 161 162 163 164 165 166 167 168 169 170 171 172 173 174 175 176 177 178 179 180 Next
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