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Lockheed under the September 28, 1970, agreement. Petitioner
further instructed Price Waterhouse that 80 percent of all other
amounts expected to be received by WHIP from other sources should
be transferred to the same account in Switzerland. Petitioner
gave similar instructions to Barclays Bank, the location of the
WHIP Barclays Bahamas account, that 80 percent of all future
deposits should be transferred to an account in the name of WHIP
at the Banque de Paris. There is no other evidence in the record
concerning the disposition of funds to or from the WHIP Swiss
account. In 1975 petitioner signed for Sunvaco and himself a
certificate of compliance under the marketing and consulting
agreement, certifying that the contract requirements had been
satisfied and that payment of $481,600 was due and owing. As
with the WHIP contracts, petitioner also directed how and to
which company payments from Lockheed on the Sunvaco contracts
were to be made.
Petitioner expended considerable effort on behalf of
Lockheed for the sale of military aircraft to the Government of
Iran. Mr. Kotchian was the President of Lockheed who originally
hired petitioner for the C-130 sale. Mr. Kotchian dealt
extensively with petitioner with regard to attempts to sell
Lockheed products in Iran, and he was under the impression that
petitioner was Lockheed's Iranian consultant. He did not know of
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