| 1. | The taxpayer had been the sole selling agent pursuant to the agreement.
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| 2. | Moreover, the brokerage firm has acted as the sole selling agent for most of stock offerings underwritten by the investment bank.
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| 3. | Agreements constituting one party sole selling agent in a defined area of the other party's goods are, of course, common.
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| 4. | FACOR signed an agreement with Marc Rich and Co . AG Switzerland, as the sole selling agent of their entire charge chrome output for 10 years.
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