J.J. Zand - Page 131

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               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               





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