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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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