AIR AMERICA, INC.

• Document Type: FOIA
• Collection: FOIA Collection
• Document Number (FOIA) /ESDN (CREST): 06148456
• Release Decision: RIPPUB
• Original Classification: U
• Document Page Count: 22
• Document Creation Date: October 23, 2023
• Document Release Date: August 10, 2023
• Case Number: F-2020-01859
• Publication Date: August 14, 1989

(b)(3)
(b)(3)
(b)(6)
Approved for Release: 2023/05/22 C06148456
0C- 4 q..-0)\730
-
ocARQQC
/ ivce,
//'e' -.4-� CENTRAL INTELLIGENCE AGENCY
Office of Congressional Affairs
Washington, D.C. 20505
Telephone: [phone] Aug 89
'u
TO: Jack Russ
Sergeant at Arms
House of Representatives
Attached is additional background
information on Air America. I hope it
is helpful.
If we can be of further assistance,
please do not hesitate to call.
1(b)(3)
1(b)(6)
FORM , 533
2-86 I OBSOLETE
PREVIOUS
EDITIONS.
f401
Approved for Release: 2023/05/22 C06148456
Approved for Release: 2023/05/22 C06148456
14 August 1989
MEMORANDUM FOR THE RECORD:
SUBJECT: Air America, Inc.
1. This memorandum concerns two related matters: (1)
recognition for Americans who were either killed or were listed
as missing and presumed dead while engaged in activities on
behalf of Air America, Inc. or associated companies in Southeast
Asia, and (2) general background information of the history of
Air America.
2. Turning first to the issue of recognition, an informal
task force was convened by the Director of Central Intelligence
in 1987 to consider an appropriate remembrance. Discussions
were held with numerous officers within the Agency, including
many with personal experience in Air America operations, and
extant Air America proprietary records were also reviewed. As a
result, it was concluded that while individual honors or an
honor roll would be ideal, the incompleteness of our records --
both as to the identity of those Air America employees who were
killed or are presumed dead in the line of duty, as well as the
circumstances of their death or disappearance -- would preclude
the creation of any individualized commemoration which would be
complete and thus equitable. It should be noted that
substantially identical reasons have also precluded
individualized honors for those members of the Office of
Strategic Services (OSS), the World War II predecessor to the
CIA, who were killed in the line of duty.
3. In light of these factors, the then Director of Central
Intelligence determined that a commemorative and honorary plaque
for Air America employees killed in the line of duty should be
commissioned and erected in the lobby of the CIA Headquarters
Building near the commemorative display for those CIA officers
killed in the line of duty. That plaque is available today for
viewing.
4. Turning to the issue of background information on Air
America and its operations in Southeast Asia, we are able to
provide the following precis of the creation, operation and
functions of this activity. We might also recommend a recent
book on Air America by William M. Leary entitled Perilous
Missions. While this book neither is an official history of Air
America nor bears any official imprimatur, it appears to be an
Approved for Release: 2023/05/22 C06148456
Approved for Release: 2023/05/22 C06148456
example of fine scholarship as well as interesting reading.
5. Air America was the largest of the CIA's proprietaries
and functioned primarily to provide air support for U.S.
operations in Southeast Asia under cover of a commercial flying
service fulfilling, inter alia, United States Government
contracts. By way of definition, proprietaries are companies Or
businesses lawfully formed, which ostensibly appear to be
private, but which are owned by the CIA and which function in
the interests of U.S. national defense and foreign policy.
Corporate headquarters for Air America and associated companies
including the overall holding corporation were in Washington,
D.C., with field headquarters in Taipei, Taiwan.
6. To fully appreciate the raison d'etre of Air America as
well as its work in support of U.S. interests requires that this
background begin in 1946 in Mainland China. There, General
Claire L. Chennault and Whiting Willauer formed a company (known
by various names but generally referred to as Civil Air
Transport or "CAT") to haul relief supplies and other cargo in
war-ravaged China and to encourage the development of an
anti-communist, western-oriented regime. After facing numerous
bureaucratic, political, financial and operational problems to
establish their airline, Chennault and Willauer were then caught
in the middle of the civil war in China in the late 1940's.
Allied on the side of the Nationalist Government, they used CAT
as a paramilitary asset in support of Chiang Kai-shek and the
civilian populations in the areas of China under his control.
Operating a fleet of well-used C-46 and C-47 aircraft, and
flying with the most primitive support facilities and with
non-existent navigational aids, CAT pilots were truly
responsible for saving the lives of hundreds of thousands of
Chinese. Their exploits of flying into unimproved 2000 foot
runways hacked from a mountain side while under fire from
communist forces in order to bring food and medical supplies to
beleaguered cities is worthy of the greatest praise. From the
evacuation of Mukden to the siege of Taiyuan, CAT unfailingly
supported and aided the Nationalist population and forces and
was, in the opinion of many, responsible for saving thousands if
not millions of lives and for insuring the survival of a free
Chineese government.
7. When resistance on the Mainland collapsed in 1949, CAT
aided in the retreat to Taiwan of the Nationalist Government.
It was at this time that the Central Intelligence Agency began
its efforts to save CAT and deny its assets to the Communists.
The CIA first arranged financial assistance to the company in
1949 and these were eventually credited to the Agency's purchase
of the corporation. By summer of 1950, the owners had come to
Washington twice to indicate their desperate needs for
additional funds in order to continue operations. With the
determination that the CIA did in fact need to contract for air
transport in some of its operations and that there would be a
continuing need for secure airlift and with there being a
general consensus that the loss of this airlift to the Chinese
Approved for Release: 2023/05/22 C06148456
Approved for Release: 2023/05/22 C06148456
communists would substantially assist them, the CIA made the
decision to exercise their purchase option. In so doing, the
CIA also sought and obtained approval from the Department of
State.
8. Subsequent to the purchase, CAT's (later to be known as
Air America) business consisted substantially of CIA cargo
carriage and was not organized particularly to fly common
carriage and thus had no status in the international air
business. This, of course, was inconsistent with its commercial
image so the airline sought and received foreign government
approvals to fly particular routes. With the new ownership and
mission and several DC-4's, Air America began modest operations
between Hong Kong, Taipei and Tokyo. Later, the corporation
acquired DC-6's.
9. While at the time of the airline's purchase, the Agency
had formed a Delaware corporation to buy it and hold title,
there were concerns about the technical organization of the
company and its management. Thus late in 1954 after a thorough
review, a new organization, designed to be more responsive to
the CIA and the Operations Directorate, was created -- the
Pacific Corporation, Air America, Inc., and Air Asia, Ltd. And,
in order to comply with various foreign investment requirements
and to make it appear that the company was majority-owned and
controlled by Chinese, the Pacific Corporation held title to
only 40 percent of the equity in Air America, while the
remainder was ostensibly owned by various Chinese business
interests, who gave deeds of trust to the CIA for their shares.
10. Through the years of the Viet Nam buildup, Air America
and, at the same time Air Asia, the maintenance arm of the
company, performed outstanding service both to American
interests in general and the U.S. Air Force in particular.
Flying in support of the U.S. mission in Southeast Asia, Air
America employees, many of them formerly with CAT, distinguished
themselves and were responsible for saving the lives of
thousands of Laotians and others involved in the long conflict.
11. At its peak, Air America had total assets of some $50
million and directly employed more than 5,000 individuals. The
employment figures for the entire air complex exceeded 8,000.
With the wind down of the war in Viet Nam a decision was made to
liquidate the Air America complex and the Agency conducted an
intensive search for competitive bidders. Air Asia was sold as
a going concern on 31 January 1975 while Air America and the
remainder of the complex were liquidated by the sale of assets
and the surrender of their corporate charters.
Approved for Release: 2023/05/22 C06148456
Approved for Release: 2023/05/22 C06148456
CENTRAL INTELLIGENCE AGENCY
Office of Congressional Affairs
Washington, D.C. 20505
Telephone: [phone]
TO:
A copy of the attached document was
handcarried to Jack Russ, Sergeant at Arms,
House of Representatives, on 10 August 1989
(b)(3)
(b)(6)
FORM
OBSOLETE
, 533
PREVIOUS
2-86 I
EDITIONS.
Approved for Release: 2023/05/22 C06148456
(40)
pproved for Release: 2023/05/22 C06148456
94TH CONGRESS } REPORT
SENATE
2d Session No. 94-755
FOREIGN AND MILITARY
INTELLIGENCE
BOOK I
FINAL REPORT
OF THE
SELECT COMMITTEE
TO STUDY GOVERNMENTAL OPERATIONS
WITH RESPECT TO
INTELLIGENCE ACTIVITIES
UNITED STATES SENATE
TOGETHER WITH
ADDITIONAL, SUPPLEMENTAL, AND SEPARATE
VIEWS
APRIL 26 (legislative day, APRIL 14), 1976
U.S. GOVERNMENT PRINTING OFFICE
69-983 0 WASHINGTON : 1976
For sale by the Superintendent of Documents, U.S. Government Printing Office
Washington, D.C. 20402 -Price $5.35
pproved for Release: 2023/05/22 C06148456
pproved for Release: 2023/05/22 C06148456
VI
Page
VIII. COVERT ACTION 141
A. Evolution of Covert Action 143
B. Congressional Oversight 149
C. Findings and Conclusions 152
IX. COUNTERINTELLIGENCE 163
A. Counterintelligence: An Introduction 163
B. Current Issues in Counterintelligence 171
C. Conclusions 177
X. THE DOMESTIC IMPACT OF FOREIGN CLANDESTINE
OPERATIONS: THE CIA AND ACADEMIC INSTITUTIONS,
THE MEDIA, AND RELIGIOUS INSTITUTIONS 179
A. Covert Use of Academic and Voluntary Organizations 181
B. Covert Relationships with the United States Media 191
C. Covert Use of U.S. Religious Groups 201
XI. PROPRIETARIES 205
A. Overview 206
B. Structure 207
C. Operation of Proprietaries 234
D. The Disposal of Proprietaries 236
E. Financial Aspects 247
F. Some General Considerations 251
XII. CIA PRODUCTION OF FINISHED INTELLIGENCE 257
A. Evolution of the CIA's Intelligence Directorate 259
B. The Intelligence Directorate Today 265
C. The Relationship Between Intelligence and Policy 266
D. The Limits of Intelligence 268
E. The Personnel System 269
F. Recruitment and Training of Analysts 270
G. The Intelligence Culture and Analytical Bias 270
H. The Nature of the Production Process: Consensus Versus
Competition 271
I. The "Current Events" Syndrome 272
J. Innovation 273
K. Overload on Analysts and Consumers 274
L. Quality Control 276
, M. Consumer Guidance and Evaluation 276
\ N. The Congressional Role 277
XIII. TfIE CIA's INTERNAL CONTROLS: THE INSPECTOR GEN-
ERAL AND THE OFFICE OF GENERAL COUNSEL 279
� A. The General Counsel 280
B. The Office of the Inspector General 289
C. Internal and External Review of the Office of the Inspector
General 303
XIV. THE DEPARTMENT OF STATE 305
A. Origins of the State Department Intelligence Function 305
B. Command and Control 308
C. Support Communications 315
D. Production of Intelligence 315
XV. DEPARTMENT OF DEFENSE 319
A. Objectives and Organization of the Defense Intelligence Com-
munity 320
B. The Defense Intelligence Budget 328
C. Management Problems of the Defense Intelligence Com-
munity 341
D. Agencies and Activities of Special Interest 349
E. Military Counterintelligence and Investigative Agencies 355
F. Chemical and Biological Activities 359
G. Meeting Future Needs in Defense Intelligence 363
XVI. DISCLOSURE OF BUM
TELLI GENCE COM'
A. The Present Budgetv
Agencies and Its C,
B. The Constitutional L
C. Alternatives to Conce
and the Public____,
D. The Effect Upon N
Budget Disclosure
E. The Argument that
Inevitably Result .1
F. The Argument that
Information on Its
Government in the
G. Summary and Conchl
XVII. TESTING AND USE CI
AGENTS BY THE IN
A. The Programs Invest'
--B. CIA Drug Testing 13,e
C. Covert Testing on H
Groups
D. Cooperation and Coal
cies, and Between
Institutions
XVIII. SUMMARY: FINDING'
A. Introduction
B. General Findings
C. The 1947 National S.)
D. The National Securit
E. The Director of Cew
F. The Central Intellige
G. Reorganization of the
H. CIA Relations with
Citizens
I. Proprietaries and Co'
J. Intelligence Liaison__
K. The General Counsel
L. The Department of I
M. The Department of S
N. Oversight and the In
0. Chemical and Biolog
munity
P. General Recommend
APPENDIX I: Congressional At
Agency to Conduct Covert Act
A. The National Securit
B. The CIA Act of 1949
C. The Provision of Fun
D. The Holtzman and A
E. The Hughes-Ryan A,
F. Conclusion
APPENDIX II: Additional Cove
A. Statement of Clark
B. Statement of Cyrus'
C. Statement of David .
D. Prepared Statement
E. Recommendations o
Politics, Study Gr4
F. Recommendations ol
gence Concerning
G. Article from Foreigt
Secret Operations:
H. Article from Saturda
with the CIAL
I. Recommendations a
the Government
Murphy Commiss
Approved for Release: 2023/05/22 C06148456
organization and re-
is needed.
of project funds or
of CCS has told the
abuse are (1) corn-
CCS; and (3) dis-
al committees.20
utlined by. the CCS
have the list of
people, and if I
any of the corn-
couple of times
't which I knew
)ard no, this in-
t. And if we had
hat indicated a
or wouldn't buy
.tinue in some form
is the best that can
of funds for these
nongovernmental if
of investment by an
ders that its funding
ernment Security
1,1974.�The insur-
its in both domestic
3 the gamut of notes,
have also used this
al and insuring ade-
general merchandise
States Government.
f.e of Logistics.
ial business and only
vested over $100.000
purchases arms, am-
ice of Logistics. This
Feadquarters officials
,ration had invested
I to an Agency em-
oyee had ostensibly
the Agency. As of
he administrative plan
divesture of American
p roved for Release: 2023/05/22 C06148456
219
December 31, 1974, this corporation had invested more than $30,000
in a certificate of deposit.23 An investment proprietary, which was later
dissolved, had invested about $100,000 in Mexico as of March 3111973.
A Delaware corporation, which has provided secure air support for
Agency employees and classified pouches between Headquarters and
other Agency facilities in the T.Tnited States, has nearly $150,000 M-
vested in a certificate of deposit.
A former youth activity proprietary, in which the Agency no
longer retains an interest, had approximately $50.000 invested in time
deposits as of March 31. 1972. Another proprietary is part of a com-
plex managed by the Cover and Commercial Staff which provides
operational support. for foreign operations. It is a Delaware cor-
poration used to collect proceeds from the sale of Agency proprietary
entities and to refund such proceeds to the Agency. Its total assets
were nearly three-quarters of a million dollars and its total stock-
holders equity was in excess of $15,000 as of December 31. 1973. It
has no employees. As of December 31, 1974, it had invested almost
half a million dollars in a convertible subordinated debenture from
the sale of a company and almost $50,000 in notes receivable.
Another company in this complex is a foreign company which has
been used as an investment vehicle for funds earmarked for new com-
mercial operations requiring Agency investments, This investment
project has been terminated and all funds were returned to the Agency.
The company has no employees. As of December 31, 1973, it had in-
vested nearly a quarter of a million dollars in a Security Note of a
private domestic corporation.
A proprietary which was part of the air support complex had in-
vested over $200,000 in a certificate of deposit. as of December 31, 1974.
This entity was later sold. Another is part of the management. and
accounting complex. As of December 31, 1974, it had nearly half a
million dollars invested in time deposits.
The Air Proprietaries
History .�Lawrenee R Houston. fomrer CIA General Counsel,
was involved in the establishment of the first set of Agency proprie-
taries' and has concluded that they should be a mechanism of last
resort. Houston maintains that the Agency learned this "the hard
way and almost all of the lessons involved probably came out one way
or the other in connection with a major aviation proprietary in the
Far East. Others bad their own special problems. but I think the Air
America complex had pretty near everything." 24
The Agency acquired Air America in 1949 ostensibly to deny the
assets of this company to the Communist Chirese. The CIA first ar-
ranged cash advances to the company in 1949. These advances were
eventually credited to the Agency's purchase of the corporation. At
that time, Houston described the airline as follows:
This normal aviation organization, this would have no mean-
ing at all, was completely at all, it would have no standing
" The Agency today uses this firm for the purchase of airline tickets for travel
in support of sensitive projects. It is estimated by the Agency that CIA business
represents about 30 percent of the gross airline ticket sales of the entity on an
annual basis.
Houston, 1/15/76, p. 5.
Release: 2023/05/22 C06148456
Approved for Release: 2023/05/22 C06148456
220
in international law, aviation rights, or any of that. But it
worked for what they wanted, which was to take supplies up-
country into inland China and Chen to bring back whatever
cargo they could get commercially: tallow, hides, bristles, all
that sort of trade, and then they traded that off for their own
account. And for awhile the operation was fairly successful,
the C-17's and C-46s.26
To finance this activity the lawyer for the airline organized a com-
pany, Civil Air Transport, which was funded by a Panamanian cor-
poration. The two owners of Air America approached the Agency in
connection with a foreign operation in the spring of 1959, and in-
dicated that unless they received financial assistance, the airline would
go out of business.
A series of meetings were held subsequently in which it was deter-
mined that the Agency needed to contract for air transport in some of
its operations, particularly those involving arms and ammunition.
And so we entered into an arrangement, I think in about Sep-
tember of 1949 whereby we would advance them, the figure of
$750,000 sticks in my mind, against which we could draw for
actual use of the planes at an agreed on rate.... And we did
draw down. I think, all the flying time and expended the
$750,000 between September and about January, at which
time we suspended any further payments or draw-downs.
I think the money was exhausted.26
The owners came to Washington in early 1950 for a series of discus-
sions with the CIA. As a result of these negotiations, the Agency agreed
to advance more funds, and received an option to purchase the assets
of Civil Air Transport. Any unused portion of the advances was to
be credited toward the purchase price. Air .America, operated under
this arrangement until the owners "came in in the summer of 1950
and said again they were in desperate straits for funds." 27 An-
other series of meetings was held at the Agency in which it was con-
cluded that the operations in the Far East would have a continuing
need for secure airlift. There was also a general estimate that the loss
of this airlift to the Chinese Communists would substantially assist
them. Thus "the Agency then made the decision that they would ex-
ercise the option given there was no objection otherwise." 28
The Agency felt that it was necessary to obtain approval from the
Department of State, so the head of the CIA's Office of Policy Coordi-
nation (who was responsible for conduct of covert actions) and Mr.
Houston visited the Assistant Secretary of State for the Far East:
He and I went to see [the Assistant Secretary] and explained
the situation. And [he] reminded us that it was basic U.S.
policy not to get the government in competition with U.S.
private industry. But under the particular circumstances,, in
particular as there was really no U.S. private industry in-
Ibid.. p. 6.
" Ibid., pp. 7-8.
27 Ibid., p. 8.
" Ibid., p.9.
pproved for Release: 2023/05/22 C06148456
pproved for Release: 2023/05/22 C06148456
221
volved in the area. and they agreed it. was important to deny
the assets to the Red Chinese. State would (To along on the
understanding that we would divest ourselves of the private
enterprise as soon as such a divestment was feasible, and
all of the circumstances that might obtain.29
The divestiture of these air proprietaries was not initiated until
1975. and some of the entities have not yet been fully divested. Mr.
Houston noted, however, that:
We did not disregard that guidance because after very con-
siderable, use of this asset during the early '50's, there was a
question of whether to continue it, and the matter was taken
up in the National Security Council. And Allen Dulles, as
Director, proposed that we continue the ownership and con-
trol of the assets of Air America, as it then was known includ-
ing the subsidy as needed. And there was a subsidy at that
time. . . . It was about $1,200,000 per year.3�
The National Security Council considered whether this asset should
be retained in 1956 and, on Dulles' recommendation, decided to con-
tinue the subsidy to Air America.
The air proprietary's business consisted almost entirely of Agency
cargo carriage under contracts carrying military designations. The
company was not organized, according to Houston, to fly common
carriage and had no status in the international air business. The evi-
dence indicates that during the early 1950s. there were two internal
struggles: one was where control should lie in the Agency, and the
other was what policies should apply to the operation of the company
itself:
The struggle within the Agency ranged all the way from
sort of quiet management discussions as to what was good
management, to sometimes rather vociferous arguments of
who's in charge here. And the operators always said, "Well,
we need to call the shots because it's our operation. . . . And
this is what we were running into all the time, of red hot
operators opposed to what we would consider good man-
agement.'
The air proprietary was managed by elements of the Office of Policy
Coordination. From the very outset there were problems in this man-
agement structure. One such example is the acquisition of Air Amer-
ica in August 1950. Houston was participating in the negotiations at
the invitation of the Head of the Office of Policy Coordination.
OPC was a curious organization, determined as being
attached to the Agency for quarters and rationing with policy
29 Ibid., pp. 9-10.
Ibid., p. 10.
Houston indicated that there had been a subsidy running to the entities since
1949. "$1.2 minion represented about the maximum subsidy given until. I believe.
about 1958 was the turning point, and from 1958 on, there was no subsidy as such
that went into it." The reason for that, of course, was that the air complex had
become "money-making."
Ibid., pp. 12-13.
Release: 2023/05/22 C06148456
i *proved for Release: 2023/05/22 C06148456
222
guidance from State, which was an impossible situation.
Very nice fellows were doing the negotiating with
[OPC] ... quite unknown to me, when they made the agree-
ment to purchase carrying out the option, they gave the
vendors the right to repurchase at any time within two years.
And I thought this was really inconsistent with our whole
position. And during the next two years they negotiated
out that repurchase agreement and in its place substituted
an agreement to give them a first refusal, if we were to dispose
of the airline. That first refusal plagued us for years. They
used to make all sorts of extraordinary claims under it and it
was never exercised and eventually it was sort. of forgotten
when [the owners] died. It ran to them personally, whether
it ran to them and two others personally, and they all are dead
now. But this shows a part of the learning curve, which was
the thing we were going through.32
In the summer of 1954. Houston and a consultant traveled to the Far
East to observe the operation. The consultant went "specifically to
look at the organization of the airline." At the time of the airline's
purchase, the Agency had formed a Delaware corporation to buy it.
The corporate counsel and the consultant were both very concerned
about the technical organization, or lack of it, in the operation. Accord-
ing to Houston, they demonstrated:
to my satisfaction that it was an absolute situation and that
no one out there had the slightest understanding of the
problem or what they were up against, or wanted to do any-
thing about it. in terms of airline management]."
Following this review, a new organization. designed to be more
responsive to the Operations Directorate. was created.
Pacific Corporation held title to 40 percent of the equity in Air
America. while the remainder was ostensibly owned by Chinese, who
gave deeds of trust to the Agency for their shares. For purposes of
international law this overt arrangement demonstrated that. the com-
pany was majority-owned and controlled by Chinese.
Air America originally had several DC-4's and began modest opera-
tions between Hong Kong, Taipei and Tokyo. The corporation soon
acquired DC-6's, and it was at this time that the question of competi-
tion with private corporations first arose. Northwest Orient Airlines
was then flying to Tokyo. Seoul. and Manila. A. Northwest executive
had noted the Agency's interest in this area when he was Chairman of
the Civil Aeronautics Board in the late 1940s and early 1950s. Houston
told the Committee :
He became head of Northwest, a very tight manager, a very
capable fellow. and be. used to complain that we were inter-
ferring, we were taking passeng-ers off his airline, and we
would go to him and say, we. have to keep the airline in this
business because the. Chinese say they need an international
airline. They're not ready to start their own yet. And it is
Ibid.. pp 13-14.
Ibid., p. 17.
Approved for Release: 2023/05/22 C06148456
pproved for Release: 2023/05/22 C06148456
41111"1191.'
223
necessary to its overall cover status as a going commercial
concern.34
By 1959 the executive had decided to ask the Civil Aeronautics
Board for a decision. A meeting was held with the entire Board, where
the executive maintained "that he was a private industry, he should
not be interferred with by government competition." 35 The Agency
explained its situation, the need for cover, and their efforts to restrict
carriage to the minimum necessary to retain their cover.
And it ended up by one of the members of the Board turning
to [the executive] and saying, "You ought to be glad that
you don't have a really good, reliable competitor in there."
He said, "If you were being competed with by private busi-
ness, you'd have real headaches. You ought to be real glad
that it's not worse than it is." 36
In these proceedings, Houston conceded that some passengers were
traveling on CIA aircraft rather than Northwest planes, but main-
tained that the impact was minimal and unavoidable. The CAB par-
ticipated in discussions with both the Agency and Northwest. After
hearing both sides, the CAB "came down on the side of the Agency
after making a reasoned judgment.""
By 1960 the airline's international commercial business was not mak-
ing money. Maintenance work in Taiwan, however, was "normally a
money-maker, and this was [contracted] primarily, although not
exclusively, with the U.S. Air Force." 38
There were management problems in the maintenance operation,
which originally stemmed from the fact that field personnel were not
particularly astute in setting costs for their contracts. Houston cited
one instance when the Aftency consultant replaced a corporation comp-
troller who was very able, but "had his own ideas of bookkeeping and
controls." The consultant insisted that the corporation implement
bookkeeping practices and controls consistent with CAB and FAA
regulations. The military maintenance contracts were constantly
audited by on-site tearns.35
In the early 1960s, the CIA received an exemption from the Con-
tract Renegotiation Board on the grounds that renegotiation personnel
might recognize that Air America was not a commercial operation
and discover that the CIA was involved. The Agency went to the head
of the Contract Renegotiation Board with a letter from the Depart-
ment of Defense requesting an exemption on what it considered "per-
fectly legitimate grounds." 40 There was indeed a basis for exemption
under the Renegotiation Act as the business was conducted entirely
overseas, and the exemption was granted. The Agency was concerned
that it had made a type of profit (over 40 percent on the Air Force
maintenance contracts), which may well have been the subject of rene-
34 Ibid.. p. 21.
as Ibid., p. 22.
'a Ibid. pp. 22-23.
p. 24.
aa Ibid., p. 25.
" Ibid., p. 26.
4� Ibid.
Approved for Release: 2023/05/22 006148456
pproved for Release: 2023/05/22 C06148456
224
gotiation, had it not been subject to the exemption. "So the question
was what to do about it. And finally, we made a voluntary repayment
against part of the profit on that contract to the Air Force." 41
As noted previously, the commercial airline aspect of the operation
operated mostly at a loss. While there were periods when Air America
cargo carriers were very busy on CIA contracts, the Korean War,
Diem Bien Phu, and other paramilitary operations; there were also
periods between these activities when there was nothing for the air-
lines to do. During these periods of inactivity, the airline was still
saddled with expenses such as crews' salaries and the maintenance of
grounded aircraft. To alleviate this problem,
. . . we finally organized the stand-by contract, which was an
apparent military entity on Okinawa. It was our entity, but
it had a military designation. I can't remember the name for
it. And that entity contracted with Air America. for so many
hours of cargo stand-by to be available any time on call, and
that they would pay so much for that capability being main-
tained . . . so that is how we kept the subsidy going to main-
tain them during periods when there was not profitable
flying..42
Another area of concern was the proprietary's relationship with the
Internal Revenue Service. From the outset, the company's manage-
ment was informed that they would be required to pay appropriate
taxes. While there were the usual arguments about whether certain
items were appropriate for taxation and whether certain deductions
should have been granted, the relationship maintained with the IRS
was basically a normal one.
Houston recalled that in the mid-1950s Air America received notice
of an upcoming audit by the IRS. Company officials came to the
Agency and indicated that this might pose a security problem. The
CIA went to the Commissioner of the Internal Revenue Service and
indicated that they wished to have the audit conducted by an IRS
team on an unwitting basis to see what they could learn. "We thought
it would be a good test of the security of our arrangements." 43 Later,
the IRS personnel would be notified that they had begun to audit an
Agency proprietary, and the audit would be discontinued:
They put a very bright young fellow on and he went into
it. They came up with discrepancies and things that would
be settled in the normal tax argument, corporate-IRS argu-
ment, and all of these were worked eventually, and then we
went to this fellow and said. "Now, this was owned and
backed by the CIA, the U.S. Government. What was your
guess as to what was happening?"
And he. said, "Well, I knew there was something there. and
I thought, what a. wonderful asset it would be for the Ibis-
sinns to have. but I came to the conclusion that it was Rocke-
feller money." 44
41 Mid., p. 27.
`2 Ibid., p. 29.
p. 30.
"Ibid.
7-
Approved for Release: 2023/05/22 C06148456
pproved for Release: 2023/05/22 C06148456
As the operations of Air America developed, problems arose in-
volving large cargo carriers. In the early days of its operation the
airline used C-54's, which had an extremely limited range, but were
able to perform under demanding circumstances. Discussions pro-
ceeded during that period about modernizing the equipment and the
Agency, through Air America, bought DC-6AB's. These aircraft were
a conversion of the DC-6 with large cargo doors installed. Air
America did not maintain any jet equipment at that point.
In the early 1950's Air America became deeply involved in a mili-
tary Air Transport System. This system was originally known as
MATS, and later as MAC.
They got MATS contracts, and Air America got these, and
these were very good to keep a constant utilization at a good
rate, the MATS rates were usually good, because the policy
was not to do competitive bidding for the lowest bidder be-
cause then you got the poorest service, but give good rates to
the carriers, and then require the carrier belong to the Civil
Reserve Air Fleet."
In 1956 MATS changed its policy and required that bidders on their
contracts be certified. Because Air America could not become certif-
icated, the Agency decided to purchase Southern Air Transport.
While this corporation was technically a separate entity, not involved
with Air America, it was actually an integral part of the complex
from a management perspective. All management decisions for South-
ern Air Transport were made by the same CIA consultant and ad-
visory team that established Air America policy.
Eventually, MAC decided to require that bidders not only be certif-
icated, but that they also have equipment qualified for the Civil
Reserve Air Fleet, i.e., jet aircraft. As a result. the Agency acquired
Boeing 727's and convinced Boeing to modify the 727 by enlarging the
ventral exit, enhancing its airdrop capability.
So the theory was that the 727's would be used on MAC con-
tracts to be available on an overriding basis if needed for
major national security operation. The, were peed. usu-
ally when they had spare time. To my recollection, they were
only called off once, off the actual contract time, and this was
for a possible use which didn't p:o through. But the White
House asked if we had the capability to move something from
here, to there, I think from the Philippines to somewhere
in Southeast Asia. I don't recall, and so they sent word to
manacrement that they wanted a plane available at the earliest
onnortunitv at Clark Field. They nulled one of them off the
MAC contract and had it available. I think ready to go, in
twelve hours. all set for the operation. And the operation
was never called. But it showed what the capability was. And
what they had to do was get substitute service for the MAC
contract."
During the late 1960s several Chinese airlines began operations on
a limited scale. With the establishment of these indigenous airlines
45 /hid_ 3R.
6' Ibid., p. 39.
Approved for Release: 2023/05/22 C06148456
'proved for Release: 2023/05/22 C06148456
226
flying Far East routes, the CIA considered reducing its international
carriage work. The Agency decided to retain the MAC contracts be-
cause they did not compete with the native enterprises, but plans to
reduce Air America's international common carriage were initiated.
Another CIA proprietary, Civil Air Transport Company, Ltd..
which had been organized in 1954, had been the first Agency entity
to engage in commOn carriage. Later, Air America did the American
contracting, followed by Southern Air Transport which also per-
formed MAC and MATS contracts with planes leased from Air
America.47
Houston noted that in the late 1960s an internal decision was 'made
that:
. . . we probably couldn't justify this major airlift, with the
big jets, and so we started getting rid of them. See, they had
no utilization to speak of down in Southeast Asia. A couple
of supply flights went into [another area] and I think we used
prop planes for that, to my recollection.47a
So the Agency began to phase out the 727s, which contributed to the
decision to divest itself of Southern Air Transport and Air America.
Internal management was streamlined in 1963 by the establishment
of an executive committee consisting of the boards of directors of the
Pacific Company, Air America and Air Asia. The overt board of
directors in New York City passed a resolution organizing an overt
executive committee, which consisted of the CIA consultant and
two other directors. Covertly, the Agency added its own representa-
tives to this committee, which allowed representatives of manage-
ment, Agency and the operators to meet, consider policies, and give
guidance. to the company. Houston indicated that this mechanism
was extremely effective in controlling the company:
So I think for the last, oh, fifteen, eighteen years, the pro-
prietary management system was on the whole pretty effec-
tive from the Agency point of view. I think we knew what
was going on. I think we were able to get things up for de-
cisions, and if we couldn't resolve them at the staff level,
we would take them up to the Director for decisions; quite
different from the early days in the early 50's that I de-
scribed, and the operators at least made the claim that they
had the right to call the tune.48
During this period of time Operations Directorate personnel
were getting themselves involved in the acquisition of air-
craft and which were getting awfully damned expensive at
this time, and separate projects were going after some of this
expensive equipment without consideration of what might
be available elsewhere to the Agency by contract or old air-
craft. And so the Director of Central Intelligence set up
EXCOMAIR, of which I was Chairman, and had repre-
sentation from both the operation and management and fi-
" SAT actually owned one 727 and leased two from Air America.
"a Aid., p. 42.
48 Ibid., pp. 46-47.
Approved for Release: 2023/05/22 C06148456
pproved for Release: 2023/05/22 C06148456
227
nance out of the Agency, to try and coordinate the overall
control and acquisition and disposition of aircraft.49
A February 5, 1963 memorandum entitled "Establishment of Execu-
tive Committee for Air Proprietary Operations," noted that the com-
mittee was "to provide general policy guidance for the management of
air proprietary projects, and review and final recommendations for
approval of air proprietary project actions." Houston indicated that
this. committee, dubbed EXCOMAIR, "was . . . an amorphous
group" which worked on a very informal basis. He indicated that
EXCOMAIR was an effective method of achieving overall coordina-
tion; it was responsible for conducting a thorough inventory of all the
equipment that the Agency had in the aviation field and was generally
able to keep track of who needed what.5� 1
According to Houston, a general shift in thinking at the Agency
occurred between 1968 and 1972 as to the desirability of maintaining
a substantial airlift capability. The records appear to indicate that
Houston convinced the Director in the early 1970s that such a capacity
was no longer necessary to retain. Houston commented on thiSassess-
ment as follows:
Through what knowledge I had of the utilization of the vari-
ous assets, it seemed to me that utilization, particularly
of large assets, that is, heavy flight equipment, was going
down to the point where there was very little of it. Con-
sequently, we couldn't forecast a specific requirement. Such
requirements as you could forecast were highly contingent.
But I also remember a couple of times putting the caveat into
the Director that with a changing world and with the com-
plications in the aviation field, once you liquidate it, you could
not rebuild2 and so you ought to think very, very carefully
before getting rid of an asset that did have a contingent
c,apability.51
Allegation of Drug TraSeking.�Persistent questions have been
raised whether Agency policy has included using proprietaries to
engage in illegal activities or to make profits which could be used to
fund operations. Most notably, these charges included allegations that
the CIA used air proprietaries to engage in drug trafficking. The
Committee investigated this area to determine whether there is any
evidence to substantiate these charges. On the basis of its examination,
the Committee has concluded that the CIA air proprietaries did not
participate in illicit drug trafficking.
As allegations of illegal drug trafficking by Air America personnel
grew in the spring and summer of 19727 the CIA launched a full-
scale inquiry. The Inspector General interviewed a score of officers at
CIA headquarters who had served in Asia and were familiar with the
problems related to drug trafficking. After this initial step, the Office
of the Inspector General dispatched investigators to the field. From
'August 24 to September 10, 1972, this group travelled the Far East
'Ibid., p. 51.
6� Ibid., p. 52.
61 Ibid., p. 57.
Approved for Release: 2023/05/22 C06148456
pproved for Release: 2023/05/22 C06148456
228
in search of the facts. They first visited Hong Kong, then eleven
Agency facilities in Southeast Asia. During this period they inter-
viewed more than 100 representatives of the CIA, the Department of
State, the Agency for International Development, the Bureau of Nar-
cotics and Dangerous Drugs, the U.S. Customs Service, the Army, Air
America, and a cooperating air transport company.
This inspection culminated in an Inspector General's report in Sep-
tember 1972, which concluded that there was
no evidence that the Agency, or any senior officer of the
Agency, has ever sanctioned or supported drug trafficking
as a matter of policy. Also, we found not the slightest suspi-
cion, much less evidence, that any Agency officer, staff or
contract, has ever been involved in the drug business. With
respect to Air America, we found that it has always
forbidden, as a matter of policy, the transportation of contra-
band goods aboard its aircraft. We believe that its Security
Inspection Service, which is used by the cooperating air
transport company as well, is now serving as an added deter-
rent to drug traffickers.52
But there were aspects of the situation in Southeast Asia which were
cause for concern:
The one area of our activities in Southeast Asia that gives
us some concern has to do with the agents and local officials
with whom we are in contact who have been or may be still
involved in one way or another in the drug business. We are
not referring here to those agents who are run as penetrations
of the narcotics industry for collection of intelligence on the
industry but, rather, to those with whom we are in touch in
our other operations. What to do about these people is a par-
ticularly troublesome problem, in view of its implications
for some of our operations, particularly in Laos.53
The Inspector General noted that there was a need for better intelli-
gence not only to support American efforts to suppress drug traffic in
Southeast Asia, but also to provide continuing assurance that Agency
personnel and facilities were not involved in the drug business.
His report began by placing the allegations against the CIA in his-
torical perspective. It allowed that when the United States arrived
in Southeast Asia "opium was as much a part of the agricultural infra-
structure of this area as was rice, one suitable for the hills, the other
for the valleys.""
The record before the Inspector General clearly established that offi-
cial United States policy deplored the use of opium as a narcotic in
Southeast Asia, but regarded it as a problem for local governments.
It was equally clear that Agency 'personnel in the area recognized its
dangers to U.S. paramilitary operations and "took steps to discourage
CIA Inspeetor General's Report. "Investigation of the Drug Situation in
Southeast Asia," 9/72. p. 2.
" Ibid., pp. 2-3.
"ibid., p. 5.
Approved for Release: 2023/05/22 C06148456
pproved for Release: 2023/05/22 C06148456
its use by indigenous paramilitary troops." 55 For example, Meo troops
were ejected from various camps when they were caught using the
drug. But, the I. G. noted:
We did not, however, attempt to prevent its use among the
civilian population in those areas where we exercised military
control, believing that such intervention would have been re-
sisted by the tribals with whom we were working and might
have even resulted in their refusal to cooperate.56
Nor did the Agency interfere with the movement of the opium from
the hills to market in the cities farther south. In this regard, the I.G.
remarked candidly:
The war has clearly been our overriding priority in Southeast
Asia and all other issues have taken second place in the scheme
of things. It would be foolish to deny this, and we see no
reason to do so."
Although it maintained this posture, the CIA was reporting in-
formation on opium trafficking long before any formal requrements
were levied upon it. As far back as the mid-1960s, when CIA case
officers began to get a picture of the opium traffic out of Burma as a
by-product of cross-border operations, they chronicled this informa-
tion in their operational reporting. As more information came to light
in Laos and Thailand, this information began to appear in intelligence
reporting. Indeed, the Agency "had substantial assets [in two South-
east Asian countries, which] could he specifically directed against this
target when it assumed top priority in 1971." 58
Air America
As early as 1957, Air America's regulations contained an injunction
against smuggling. This regulation later came to include opium. The
Report indicated that the airline's effort at this time was concen-
trated on preventing the smuggling of opium out of Laos on its air-
craft. Although still not a crime in Laos, shipment of opium on
international flights was clearly illegal and was grounds for dismissal
of any pilot or crew member involved. The Inspector General stated
that:
Air America has had a few cases of this kind (all of which
are documented in the files in the Agency) and has, in each
case, taken prompt and decisive action upon their discovery."...
Air America was less able to control drug traffic involving its aircraft
within Laos. Although it had a rule that opium could not be carried
aboard its planes, the only thing that could be done if the rule was
violated was to put the opium and its owner off at the nearest airstrip.
" Ibid., p. 6.
" Ibid.
" Ibid.
The report related a statement of a case officer which typified the CIA position
in the matter during the period 1960-1968. The officer said that he "was under
orders not to get too deeply involved in opium matters since his primary mission
was to get on with the war and not risk souring relations with his indigenous
military counterparts by investigation of opium matters."
Ibid, p. 7.
"Ibid.
Approved for Release: 2023/05/22 C06148456
pproved for Release: 2023/05/22 C06148456
230
Moreover, as a charter carrier, Air America did not have full control
over its traffic. It hauled what its customers put on the aircraft. Air
operations officers, in the case of Agency traffic, were responsible for
authenticating the passengers and cargo they wished to put on the
plane. In some locations, the air operations officers had to rely on
indigenous assistants for much of the actual details of preparing mani-
fests, checking cargo, and supervising the loading of the aircraft. In
areas where active military operations were in progress, this process
could become cursory if not actually chaotic. In such circumstances, the
Inspector General concluded that:
it was hardly fair to blame Air America if opium happened
to get aboard its aircraft. There is no question that it did on
occasion.60
With the realization that drug abuse among American troops in
Vietnam was growing and that Southeast Asian heroin was finding
its way to U.S. markets. the CIA's early attitude toward the opium
problem began to change. The Agency joined the effort that began in
1971 to halt the flow of opium and heroin from Burma, Laos, and
Thailand, and pursued a vigorous intelligence program against these
targets.
In terms of staff and contract personnel, the Inspector General was
impressed that "to a man, our officers overseas find the drug business
as distasteful as those at. headquarters." 61 Indeed, many of the CIA's
officers were restive about having to deal with Laotian officials who
were involved in the drug business:
One young officer even let his zeal get the better of his judg-
ment and destroyed a refinery in northwest Laos in 1971 be-
fore the anti-narcotics law was passed, thus risking being
charged with destruction of private property.62
But, the I.G. reported, CIA officers generally tolerated the opium
problem, regarding it as just another of the frustrations one encoun-
ters in the area.
From what the Inspector General contingent was able to observe in
the field, "the pilots in the employ of Air America and the cooperating
air transport company merit a clean bill of health." 63 While it was
true that narcotics had been found aboard some of their aircraft, in
almost every case the small quantity involved could only have been
for the personal use of the possessor. The Inspector General felt that
Given the strict anti-contraband regulations under which
these two airlines have been operating for years, it is highly
unlikely that any pilot would knowingly have permitted nar-
cotics or any other contraband aboard his aircraft.64
Although they noted, "if it is a truism to say that they're in the
business for the money," the investigators concluded that these pilots
'33 Ibid, p.8.
e' Ibid. p. 11.
6' Ibid.
63 Ibid. p.12.
" Ibid.
Approved for Release: 2023/05/22 C06148456
pproved for Release: 2023/05/22 C06148456
231
were deeply committed to their job. and that the subject of drugs was
as much an anathema to them as it is "to any decent, respectable citi-
zen in the United States." 65
The Inspector General indicated how one pilot felt about the sub-
ject. He stated:
You get me a contract to defoliate the poppy fields in Burma,
and I'll take off right now and destroy them. I have a friend
whose son is hooked on drugs, and I too have teenage chil-
dren. It scares the hell out of me as much as it does you and
the rest of the people in the States."
The report also established that the pilots were well paid, averaging
close to $45,000 a year. Almost half of their salary was tax-free. In
this context the I.G. concluded that
Although the temptation for big money offered by drugs can-
not be dismissed out of hand, it helps to know that the pilots
are making good money. Further, an American living in
Vientiane can bank a substantial part of his salary without
much difficulty, and a common topic of conversation among
pilots is how and where to invest their fairly substantial
savings.67
The milieu in which these pilots found themselves did serve to evoke
images of them as mercenaries or soldiers of fortune. The Inspector
General indicated that a "number of them do like their wine and
women, but on the job they are all business and very much like the
average American." 68
The investigators, however, could not be as sanguine about the
behavior of the numerous other individuals who worked for Air
America and the cooperating air transport company as mechanics or
baggage handlers. The nature of their work allowed these employees
easy access to the airplanes, and created real opportunities for con-
cealing packages of narcotics in the airframes. The records indicated
that there were several instances where employees had been fired be-
cause they were suspected of handling drugs. The Inspector General
advisd that:
Despite the introduction of tighter security measures, it
would be foolish to assumeS that there will not be any further
attempts by mechanics and baggage handlers to conceal nar-
cotics on airplanes.69
In a startling revelation concerning indigenous officials in Southeast
Asia, the I.G. bitterly reported that
In recent testimony to Agency officers in Vientiane, Laotian
officials who had been involved in the drug business stated
that there was no need for drug traffickers to use Air Amer-
ica facilities because they had their own. We certainly found
Ibid.
" Ibid. p. 13.
ri Ibid.
6a Ibid. p.14.
Ibid.
Approved for Release: 2023/05/22 C06148456
pproved for Release: 2023/05/22 C06148456
232
this to be true. In addition to the Royal Lao Air Force
(RLAF), there are several commercial airlines in Laos, in-
cluding Royal Air Lines, Lao Air Development, Air Laos,
and perhaps others, all of which evidently have ties with
high Laotian government officials. It is highly problematical
whether these airlines have a full platter of legitimate busi-
ness."
Another factor which had the effect of making Air America a less
desirable target for the drug trafficker was that there were virtually
no regular, pre-arranged flight schedules for the pilots. Ordinarily.
the pilot did not know until he reported for duty which airplane he
would be flying or what his flight schedule would be for the day.
Air America's Security Inspection Service, which was established
early in 1972, also had five inspection units in Laos. Similar units
were eventually established elsewhere in Southeast Asia. Each unit
consisted of an American chief and three or four indigenous personel.
The baggage of the pilot and all passengers traveling in CIA-owned
aircraft was inspected in the presence of an American official before
anyone was permitted to board. All cargo was inspected unless it had
been exempted under established procedures. The very existence of
the system was considered a deterrent to drug smuggling on Air
America aircraft and did result in several discoveries of drugs among
the baggage of passengers, although only one or two of these involved
quantities of sufficient size to be as commercial.
Agents and Assets
This is one area. where the CIA is particularly vulnerable to criti-
cism. Relationships with indigenous assets and contacts are always
broad. In Laos, clandestine relationships were maintained in every
aspect of the Agency's operational program�whether paramilitary,
political action, or intelligence collection. These relationships included
people who either were known to be, or were suspected of being, in-
volved in narcotics trafficking. Although these individuals were of con-
siderable importance to the Agency, it had doubts in some instances.
For example, the. investigators were troubled by a. foreign official who
was alleged to have been involved in one instance of transporting
opium. He was evidently considered "worth the damage that his ex-
posure as an Agency asset would bring, although the Station insists
(a) that he is of value to the Station as an agent of influence [deleted]
and (b) that his complicity in the [de]eted] incident has never been
proved." 71
Among liaison contacts, which in the military arena included vir-
tually every high-ranking Laotian officer. the Inspector General
warned that the Agency was "in a particular dilemma."
The past involvement of many of these officers in drugs is
well-known, and the continued participation of many is sus-
pected: yet their goodwill, if not actual cooperation, con-
siderably facilitates the military activities of the Agency-
supported i rregu I a rs.72
"Ibid.
71 Ibid.
" Ibid, p. 18.
Approved for Release: 2023/05/22 C06148456
pproved for Release: 2023/05/22 C06148456
233
The Inspector General concluded, that
The fact remains. . . that our continued support to these peo-
ple can be construed by them, and by others who might become
aware of the association, as evidence that the Agency is not as
concerned about the drug problem as other elements of the
U.S. mission in Laos. The Station has recently submitted, at
headquarters' request, an assessment of the possible adverse
repercussions for the Agency, if its relationship to certain as-
sets were exposed. We think that, on the whole, that assess-
ment was unduly sanguine. We believe the Station should
take a new look at this problem, using somewhat more strin-
gent criteria in assessing the cost-benefit ratio of these rela-
tionships. We realize that it is impossible to lay down any but
the most general kind of rules in judging whether to con-
tinue, or to initiate, a clandestine relationship with Laotians.
Each case has to be decided on its own merits, but within a
framework that attaches appropriate importance to its pos-
sible effect on the U.S. Government's anti-narcotics efforts in
Laos. It is possible that the Station will need additional
guidance from headquarters as to current priorities among
our objectives in Laos.73
2.N onoperating Pro prietariee
Nonoperating proprietaries vary in complexity according to their
Agency task. They are generally corporate shells which facilitate for-
eign operations and clearly pose no competitive threat to legitimate
businesses. The most elaborate are legally licensed and established to
conduct bona fide business.
All nonoperating proprietaries do have nominee stockholders,
directors, and officers and are generally directed by one of the Agency's
proprietary management companies. The company address may be a
Post Office box, a legitimate address provided by a cleared and witting
company official or private individual or the address of a proprietary
management company. The nonoperating proprietaries maintain bank
accounts, generate business correspondence, keep books of account
which can withstand commercial and tax audit, file State and Federal
tax returns, and perform normal business reporting to regulatory
authorities. They are moderately capitalized, generally at around
$5,000, and their net worth at any one time varies according to the
Agency task they are performing. As of December 31, 1973, more than
60 percent of the combined net worth of these proprietaries was operat-
ing capital for companies which provide cover to agency personnel. Legallyincorporated companies require less elaborate commercial
administration due to the nature of the tasks they perform for the
CIA. This kind of proprietary is directly managed by headquarters
specialists operating in alias. No commercial book or accounts are kept,
and in the event of a tax audit the Agency has to brief the auditing au-
thority.
Depending on use, administration may be, as simple as maintain-
ing bank accounts and filing annual franchise taxes, or as extensive
Ibid, p. 19.
69-983 0 - 76 - 16
Approved for Release: 2023/05/22 C06148456