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The $5,000 payment to petitioner for reimbursement of certain
items listed above is also referred to in a separate 1973 letter
from Ashland to petitioner. This letter contained a check for
$5,000 and described it as a reimbursement.
The second document linking petitioner to Interrep is a
letter from Ashland to All Patents requesting verification of
payments received from Ashland and requesting confirmation that
there was no knowledge on the part of the signer (who was
petitioner) that he had made any U.S. political contributions on
behalf of Ashland. Petitioner's signature appears at the bottom
of this letter. One of the payments listed in the second
document was a $100,000 "Payment to account of Interrep, S.A. for
the group represented by Mr. James Zand". This amount from
Interrep was neither included in CTC's cash receipts journal as a
receipt nor reported as income by petitioner.
In the notice of deficiency for 1974 respondent increased
petitioner's income from Ashland by $1,472,775.68. In 1974
Ashland issued five checks in the total amount of $1,472,776.12
to or for All Patents. The stated purpose of four of the five
checks was either "commission", "commission on crude oil
purchased from NIOC", or "advice and services rendered to Ashland
Oil, Inc., in connection with purchase of oil from National
Iranian Oil Company and other business activities in Iran". The
fifth check for $900,000 was a commission payment related to the
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