Estate of Barkat A. Khan, Deceased, Mohammed Aslam Khan, Executor - Page 14

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          taxable year.  On the return, Woodmansee indicated that decedent            
          had left the United States permanently on December 24, 1986.                
          Decedent's 1986 Form 1040NR was filed with the Internal Revenue             
          Service at the Philadelphia Service Center on October 20, 1987.             
               In Pakistan, decedent found it difficult to work out the               
          agreement with Chrag.  During 1987, decedent again thought he had           
          reached an agreement.  Kutz drafted an agreement and sent it to             
          Pakistan.  Again Chrag refused to sign the agreement.8                      
               While decedent was in Pakistan, his health began to fail.              
          He was hospitalized in Pakistan from October 28 through November            
          10, 1988.  Decedent's reentry permit expired January 6, 1989.               
          Following his hospitalization, he was very weak and his health              
          continued to deteriorate.  He was hospitalized again from                   
          February 9 through February 15, 1989, and December 11 through               
          December 20, 1990.                                                          
               Aslam visited his father in Pakistan in 1990.  At that time            
          decedent was not able to walk and often needed assistance with              
          bathing and eating.  Decedent wanted to return to the United                
          States at that time, but his health would not permit him to make            
          the long trip.                                                              






               8  A final written agreement was not reached until March of            
          1993.                                                                       




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