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for interim purposes, petitioner and Dr. R. Fallah had been
nominated to the Board of Directors. However, petitioner and his
attorney later became WHIP directors. Dr. Fallah was a Director
of NIOC. Although Occidental Petroleum Corporation (Occidental)
referred to WHIP as a nominee of NIOC in a February 1969 letter
to Dr. Fallah, in a subsequent letter to another client,
petitioner referred to WHIP as "one of our operating companies".
Petitioner was able to tie this oil purchase by Iran to the
sale of Lockheed aircraft. In 1970 Lockheed indicated a
willingness to sell 24 Lockheed C-130 airplanes, including ground
support equipment, to the Imperial Iranian Air Force. The C-130
Hercules aircraft was a large military transport plane. While a
direct sale was not implemented, in 1970 an agreement was entered
into between petitioner's companies and Occidental; this
agreement was related to another agreement of the same date
between Occidental and NIOC. Pursuant to these agreements
Occidental purchased oil from NIOC; Occidental then paid for the
oil partly in cash and partly in C-130 Hercules aircraft that
Occidental purchased from Lockheed. Furthermore, according to
the agreement between petitioner and Occidental, Occidental was
to pay a fee to WHIP of 1 cent per barrel of oil that Occidental
purchased from NIOC. This fee to WHIP was "in consideration of
services rendered to date and that will continue to be rendered
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