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account, he paid Hossein Zanganeh $80,000 in 1972 for his
assistance in the Lockheed transactions. He transferred $880,000
from the WHIP account to a Swiss account at the Banque de Paris.
From the Diesel Power account at Bank of America, petitioner
withdrew $655,500 in 1973, $531,633 in 1974, $1,345,766.60 in
1975, and $665,000 in 1976.
With respect to Ashland, petitioner was paid commissions for
his consulting services in the amounts of $117,900 in 1973,
$1,472,776 in 1974, and $452,328 in 1975. In 1976, he was paid
$265,000 for the termination of the various consulting agreements
that existed with respect to Ashland's business in Iran. Yet he
reported only $66,250 of these amounts on his tax returns for
those years.
The payments by Ashland, like those by Lockheed, were made
to shell entities, primarily All Patents Corporation, through
1975. Some of the amounts made payable to All Patents were
deposited to Swiss accounts at the Banque de Paris for
petitioner's benefit. He alone performed the services for which
those commission payments were made. He transferred the funds
deposited to All Patents' Banque de Paris account to Diesel
Power's account. He also had some of the commissions made
payable to All Patents deposited directly to Diesel Power's
account. Diesel Power provided no consulting services to
Ashland, and it was not in a line of business that would have
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