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saw or knew the terms of the underlying agreements with Lockheed
and Ashland.
Petitioner was the sole representative of Lockheed and
Ashland with respect to the business these companies transacted
with the Government of Iran. These two companies paid
commissions in excess of $5 million for the services rendered by
petitioner. As a part of his scheme to evade the payment of
taxes, petitioner directed the majority of the commissions to
bank accounts in the names of other entities. He directed
Lockheed to make commission payments he earned in the amounts of
$594,972, $466,147, $995,542, and $331,862 to Diesel Power's Bank
of America account during the years 1972 through 1975,
respectively. He also directed Lockheed to deposit commission
payments he earned to the WHIP bank account at Barclays Bank
Bahamas in the amounts of $418,111 in 1972 and $191,588 in 1973.
The amounts he directed to the Diesel Power and WHIP bank
accounts were not recorded in CTC's books, nor were Lockheed,
WHIP, or Sunvaco listed as customers of Diesel Power in the
latter's financial statements for the periods ending March 20,
1974 and March 20, 1975.
Petitioner had complete control over the Diesel Power and
WHIP bank accounts. He made significant withdrawals and
transfers from the accounts during the years 1972 through 1976
which he converted to his personal use. From the WHIP bank
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