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A. Lockheed
Petitioner did business with Lockheed Aircraft Corporation
(Lockheed)6 through four entities. One entity was a corporation
located in the Bahamas called Western Hemisphere Industrial &
Petroleum Corporation (WHIP), which was formed in 1969. WHIP
share certificates were issued in the names of nominees for
petitioner, although at one point WHIP is referred to by one
company as a nominee for the National Iranian Oil Company (NIOC).
Petitioner had an ownership interest in WHIP. Price Waterhouse,
the resident agent for WHIP, was given instructions from
petitioner and was paid by petitioner. The banking and other
business activities of WHIP were handled by petitioner and his
CTC employees.
Petitioner's first expression of the idea to use the WHIP
entity appeared in a letter dated January 14, 1969, from
petitioner to Iran's then Prime Minister. Petitioner outlined
the terms of an agreement that he proposed to negotiate for the
purchase of oil by Iran, explaining that the "mechanics for
implementation" of the arrangement would involve WHIP.
Petitioner's letter also indicated that disposition of WHIP
shares would be at the discretion of the Prime Minister and that,
6 Petitioner participated in business transactions with a number of
companies and their affiliates. Respondent did not distinguish among these
affiliates in the notices of deficiency. For purposes of this opinion, it is
irrelevant which of the affiliates dealt with petitioner; therefore, we do not
distinguish between them in the findings of fact. Each company and all of its
relevant affiliates will be referred to under one generic name.
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