J.J. Zand - Page 223

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          agreements dated May 18, 1973, and December 7, 1973, between                
          Ashland and the Banque de Paris.  By these agreements Banque de             
          Paris was to provide technical advice and assistance in                     
          connection with the joint venture in exchange for a fee.                    
               Although Ashland representatives did not know who the legal            
          owners of All Patents were, it was understood by Ashland that All           
          Patents was an affiliate of petitioner.  Orin Atkins was the                
          president of Ashland from 1964 to 1981.  Mr. Atkins retained the            
          services of petitioner in Ashland's efforts to purchase crude oil           
          from Iran with the expectation that, because of petitioner's                
          fluency with the language, his familiarity with the country, and            
          his business success in both Iran and the United States,                    
          petitioner would help to facilitate the arrangement of meetings             
          with Iranian officials and help to shape Ashland strategy in                
          Iran.  Petitioner was an intermediary who helped Ashland                    
          interpret the Iranian mood in Ashland's strategy development for            
          these projects.  Petitioner also participated in negotiations and           
          helped to arrange and prepare for meetings with Iranian                     
          officials, including the Shah of Iran.  Except for a meeting with           
          the Shah, Mr. Atkins was accompanied by petitioner at almost all            
          his meetings with Iranian officials.                                        
               The primary contact person in the Iranian Government for               
          these negotiations on behalf of Ashland was Dr. Fallah, who also            
          had some involvement in petitioner's business dealings with                 





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