J.J. Zand - Page 244

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               During 1976 petitioner arranged for IMICO to be appointed              
          the dealer within a certain location in Iran for Detroit Diesel             
          Allison spare parts and engines under Diesel Power's                        
          distributorship in Iran.  Furthermore, in 1976 petitioner and CTC           
          assisted SEDCO in obtaining for IMICO a full service dealership             
          of Detroit Diesel Allison products in Iran.  Diesel Power was not           
          involved in negotiating these arrangements.  It was understood              
          between CTC and Diesel Power that Diesel Power was not entitled             
          to any commissions earned in connection with the IMICO dealership           
          project.  In 1977 Mrs. Conway of CTC wrote a memorandum to the              
          file in which she stated:                                                   
                    Due to the upheaval caused by the Lockheed situation              
               Detroit Diesel Allison and Ingersoll-Rand have advised that            
               commissions payments issued in the name of Diesel Power                
               Company can no longer be mailed to Caspian Trading Company.            
               In fact regulations have become so stringent that both                 
               manufacturers are restricted to mailing commissions to the             
               distributor in the country in which the distributorship is             
               held.  This if course means payments must be mailed directly           
               to Diesel Power in Teheran.                                            
                    Since Farshid will be in the country next week, it will           
               be necessary to establish procedure for Diesel Power to                
               receive these commission checks and to return to Caspian               
               its' share of the commission.  Caspian, of course, will                
               retain 100% of all commission on the dealership agreement              
               with Imico.  [Emphasis added.]                                         
                   H. Payments by SEDCO, IMICO, Stewart & Stevenson                   
               In the notice of deficiency for 1973 respondent increased              
          petitioner's income from Stewart & Stevenson by $1,000.  This               
          alleged payment is not reflected on the 1973 CTC receipts                   






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