J.J. Zand - Page 220

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               In a letter dated May 13, 1975, a senior vice president of             
          Lockheed sent petitioner a letter expressing concern over                   
          communications that had been brought to his attention suggesting            
          that the Government of Iran might refuse to do business with                
          companies that used middlemen, such as petitioner, in offering              
          products for sale to Iran.  Petitioner responded to Lockheed by             
          explaining that the policy of Iran was to continue doing business           
          with legitimate representatives.  In July 1975, petitioner was              
          interviewed by U.S. Senate Foreign Relations Committee personnel            
          concerning possible questionable payments to foreign government             
          officials in connection with product sales.  After this                     
          interview, the record shows no Lockheed commission payments to              
          either Diesel Power or CTC.  On January 28, 1976, the                       
          Lockheed/Zand/Sunvaco agreement was terminated effective                    
          October 10, 1975.  The termination was a result of the U.S.                 
          investigation into Lockheed's use of consultants.  The                      
          termination agreement was signed by petitioner on his own behalf            
          and on behalf of Sunvaco.                                                   
               In the notice of deficiency for 1976 respondent increased              
          petitioner's commission and fee income from Lockheed by $321,066.           
          Lockheed issued a check dated January 26, 1976, to Sunvaco and              
          petitioner in the amount of $481,600.  This check was mailed to             
          petitioner's Columbus, Ohio, address and was deposited in full              
          into the CTC CNB account.  Of this amount $100,000 was paid by              





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