- 172 - In addition, petitioner held himself out to the U.S. Senate Foreign Relations Committee as Ashland's representative through "his companies". While petitioner might have had a certain incentive to increase his own business stature by holding himself out as the owner of those companies, we think that his representation was not based on a factual foundation. At the trial, in response to a question about who received the funds from the All Patents account petitioner testified, "I have absolutely no knowledge and I didn't want to have any." By this he appeared to be implying that there may have been something improper or illegal about the arrangement between NIOC and Ashland via All Patents. But there is evidence that petitioner was Ashland's actual representative and performed the services for which payments were made. Accordingly, we hold that petitioner earned the funds received pursuant to the Ashland consulting agreement. Lastly, we note that Ashland's 1975 payments in All Patents' name were deposited to the Diesel Power Banque de Paris account, of which petitioner was an authorized signatory, rather than to an All Patents account. However, there is no evidence that Diesel Power was involved in the Ashland negotiations. We find no significance in the fact that petitioner relinquished part of his interest in Diesel Power in late 1974. If, as petitioner contends, the Ashland payments to All Patents did not belong toPage: Previous 162 163 164 165 166 167 168 169 170 171 172 173 174 175 176 177 178 179 180 181 Next
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