J.J. Zand - Page 249

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          made to the London Zand account, the Banque de Paris, and to CTC.           
          However, during 1975 Mrs. Conway of CTC canceled her prior                  
          instructions and instructed Ingersoll-Rand to send commissions to           
          the Diesel Power Banque de Paris account.  In 1975 Mrs. Conway              
          instructed Ingersoll-Rand to change the procedure again and to              
          make certain commission checks payable to a company called                  
          International Gas & Oil Supply Company, Ltd. (IGOS).  IGOS was              
          formed in 1973, and petitioner had a one-third interest in IGOS.            
          Mr. Khalatbari inquired from Ingersoll-Rand at that time about              
          procedures for transferring the distributorship to IGOS, although           
          it is unclear whether such a transfer occurred.  During 1975 Mrs.           
          Conway changed the IGOS bank mailing address to CTC's Ohio                  
          address, and IGOS bank statements were mailed to CTC at that                
          address starting in 1975.  In 1976 Mrs. Conway further instructed           
          Ingersoll-Rand that commissions were to be sent to the Zand FNCB            
          London account.  At some time in 1977, Ingersoll-Rand was asked             
          to have distributors provide confirmation that payment of                   
          commissions to locations outside their country of residence was             
          appropriate under that country's laws.  Therefore, Mrs. Conway              
          told Ingersoll-Rand that commissions could no longer be sent                
          directly to CTC.  Instead, Mrs. Conway directed Ingersoll-Rand to           
          hold the commission checks for pickup by a CTC representative.              









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