J.J. Zand - Page 267

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               In addition to petitioner's direction of commission                    
          payments, petitioner ultimately was in charge of the Galion                 
          relationship.  For example, when a question arose whether a                 
          change of control from one Iranian ministry to another would                
          affect the acquisition of certain Galion equipment, CTC told                
          Galion that the new Minister "is a good friend of Mr. Zand's, so            
          there is no difficulty by this change."  Petitioner personally              
          handled Galion sales to a ministry.  CTC employees also confirmed           
          to others the impression that CTC was ultimately responsible for            
          Galion sales by corresponding with a potential customer of Galion           
          equipment with the following language:  "Our company name in Iran           
          is Diesel Power Company."  In a letter to another purchaser of              
          Galion equipment there was a reference to "our Teheran office               
          Diesel Power".  Petitioner's ultimate authority was understood              
          among various CTC employees.  At the bottom of a letter from                
          Diesel Power to Mrs. Meier in 1976 concerning a rebate that had             
          been negotiated on some cranes by Mr. Shirazi of Diesel Power, a            
          handwritten note from "MA" says "ask JJZ"; an apparent response             
          states "pay to us here 40/60".  In 1978 there was evidence that             
          petitioner still was in control of the Galion relationship.  Mr.            
          Khalatbari did not sign a contract for the sale of Galion                   
          equipment to the Iranian ministry and was described to a CTC                
          employee by an Iranian business associate as "your man on the               







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