J.J. Zand - Page 186

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          modified to maintain the previously stated commission to "Mr.               
          Zand's companies" despite the reduction.                                    
               Another company used by petitioner in his dealings with                
          Lockheed was Sunvaco.  Mr. Conley, a Lockheed official who had              
          met petitioner in 1971, was aware that petitioner, through WHIP,            
          already was Lockheed's representative for the sale of the C-130             
          aircraft.  After this initial meeting, Mr. Conley and other                 
          Lockheed officials met with petitioner, who introduced them to              
          Mr. Khalatbari and Mr. Zanganeh, and the three said they would              
          work as a group under the name of Sunvaco.7  On June 1, 1971,               
          Lockheed entered into a marketing consultant agreement with                 
          petitioner and Sunvaco.  Initially, petitioner and Sunvaco were             
          to receive a monthly retainer in the amount of $4,166.66.                   
          Commission payments were to be set forth later.  Petitioner                 
          signed the agreement on behalf of himself and Sunvaco.  On                  
          October 29, 1971, this marketing agreement was modified to                  
          provide a 3-percent commission to be paid on sales of Lockheed              
          Model P-3 Export Type Aircraft, a military aircraft.  Further               
          amendments to this agreement and to the earlier agreement in                


          7 In 1981 petitioner wrote to Mr. Conley, who had been the president of     
          Lockheed's Tehran division, indicating that petitioner needed confirmation of
          certain information in connection with an Internal Revenue Service          
          investigation that Lockheed had engaged the services of at least three      
          individuals when it retained Sunvaco.  In response to petitioner's request, 
          Mr. Conley confirmed in writing his recollection that petitioner "did not have
          all of the desirable capabilities to act as our marketing consultant in Iran"
          and that he understood Sunvaco to involve the services of at least Khalatbari,
          Zanganeh, and petitioner.                                                   





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