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letter indicating that Diesel Power was its representative in
Iran, there is no indication that the earlier agreement with CTC
was terminated or that an agreement with Diesel Power was ever
executed. There is also evidence that this letter was issued at
the request of a CTC employee to facilitate obtaining business
with the Iranian Government and was not intended to replace the
Pioneer-CTC distributor agreement. Moreover, even if Diesel
Power were Pioneer's distributor, petitioner clearly maintained
control over the earning of Pioneer commissions. Petitioner and
CTC employees corresponded with Pioneer on matters of importance.
CTC gave Pioneer instructions on the payment of commissions.
Petitioner and CTC created and continued the impression that
Diesel Power and CTC were one and the same. Although petitioner
relinquished ownership of some of his Diesel Power stock in late
1974, he does not appear to have relinquished his control over
the earning of commissions. When Pioneer in 1974 expressed a
willingness (at Mrs. Meier's suggestion) to amend the distributor
agreement to Diesel Power's name, petitioner was asked whether
this should be done, indicating that he had the power to prevent
such a revision. Accordingly, we sustain respondent's
determinations for the years 1973 through 1977.
With regard to 1978, the parties have made no stipulations
and respondent has made no assertions apart from the notice of
deficiency in connection therewith. We assume this to be an
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