Faramarz and Mitra Elghanian - Page 7

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               4.   Events From 1977 to June 1979                                     
               Based on the experiences of some of his relatives,                     
          petitioner believed that he would be required to serve for 2                
          years in the Iranian military in order to return to Iran later to           
          deal with his family’s property.  On a date in 1977 not specified           
          in the record, petitioner returned to Iran to begin that service.           
          Petitioner’s parents lived in Iran at that time.  Petitioner left           
          a car, some dishes, photographs, and clothing in Boston, which he           
          intended to reclaim later.                                                  
               Shirley Elghanian returned to Iran with petitioner in 1977.            
          Petitioner’s daughter, Roya, was born in Iran in December 1977.             
          Because of political unrest in Iran, Shirley Elghanian and Roya             
          went to London in 1978 to live with Shirley Elghanian’s parents.            
               Petitioner’s mother and his brother, Phillip Elghanian,                
          moved to the United States in 1978.                                         
          B.   Events in 1979                                                         
               1.   The Expropriation                                                 
               In January 1979, the Shah of Iran was deposed in a                     
          revolution.  The Ayatollah Khomeini became the new leader of                
          Iran.8                                                                      



               8  For a more detailed account of these events in Iran, see            
          Contl. Ill. Corp. v. Commissioner, 94 T.C. 165 (1990);                      
          Halliburton Co. v. Commissioner, 93 T.C. 758 (1989), affd. 946              
          F.2d 395 (5th Cir. 1991); and Moshrefzadeh-Sani v. Commissioner,            
          T.C. Memo. 1992-592.                                                        





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