J.J. Zand - Page 227

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          Relations Committee, which was looking into drafting legislation            
          making it a crime to pay bribes to foreign officials, that he was           
          not aware of any improper payments to foreign officials.  He also           
          stated:                                                                     
               I emphasized the fact that it was I who sought Ashland and             
               who prevailed upon them to come to Iran and who assisted               
               them in developing their programs for Iran. * * * .                    
                                 *  *  *  *  *  *  *                                  
               I stated that ever since the inception of my relationship              
               with Ashland six years ago, my companies paid our own way              
               * * * .                                                                
          Petitioner indicated that he had told the Committee that no                 
          one in the Government of Iran had made any demands for "under-              
          the-table" payments.  On January 6, 1976, petitioner signed an              
          affidavit for an unknown purpose stating that he had not made,              
          and in the future would not make, any payments from funds paid to           
          him by Ashland that he knew or had reason to know were illegal in           
          the jurisdiction in which the payment was made.                             
                                D. Payments by Ashland                                
               In the notice of deficiency for 1973 respondent increased              
          petitioner's income from Ashland by $120,900.  In August 1973,              
          Ashland issued a wire transfer of $100,000, payable to a bank               
          account in the name of Interrep. S.A. (Interrep), account number            
          29893C.  These funds were deposited in an account at the Banque             
          de Paris.  The stated purpose for this wire transfer was                    
          "Consulting done in relation to Iranian Venture".                           





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