- 21 -
In January 1978 Mr. Khalatbari withdrew all funds from and
closed the Diesel Power FNCB Geneva # 1 account and Diesel Power
Banque de Paris account. In March 1978 a second payment on the
Diesel Power stock sale was made by Mr. Khalatbari in the amount
of $625,000. The remaining payments due to petitioner under the
stock sale agreement were $700,000 in December 1978 and $265,000
in December 1979.
In May 1978 petitioner ordered a total of $240,000
transferred from an account at the Banque de Paris into the WHIP
Barclays Bahamas account. After ordering these funds to be
invested in a certificate of deposit, petitioner redeemed this
certificate of deposit prior to its maturation, as well as
another certificate of deposit in the amount of $361,211, and
ordered that the proceeds be deposited in the WHIP Barclays
Bahamas account. In December 1978 Mr. Dutton, on petitioner's
instructions, flew to the Bahamas and withdrew $610,000 from the
WHIP Barclays Bahamas account and deposited these funds into one
of petitioner's accounts in Ohio. These funds were not recorded
on the CTC receipts journal or petitioner's 1978 return or 1978
amended return. Mr. Dutton performed another analysis in 1979
from which he concluded that CTC was in possession of more than
$1,600,000 in Diesel Power commissions. On his return for 1979
petitioner reported $1,617,761 as income, claiming that Diesel
Power shareholders owed him a considerable amount on the sale
Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 NextLast modified: May 25, 2011