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tugboats, and a warehouse. GMS also leased the cranes and
equipment to other companies.
Sale of GMS
Since petitioners were considering moving to the United
States, petitioner claimed that during 1975 and 1976, he
negotiated to sell GMS to Ammareh. At some point in 1976,
petitioner and Ammareh allegedly orally agreed to the sale for a
price of $8 million, which Ammareh allegedly would pay petitioner
with money earned from the business. This sale was not evidenced
by any written agreement. Petitioner did not report the sale on
his 1976 Iranian tax return.
Iran-Iraq War
War broke out between Iran and Iraq in September 1980 and
lasted until 1988. Khorramshahr and surrounding areas were
attacked by Iraqi air and ground forces. The city was captured
by Iraq and was devastated. GMS’s assets were largely destroyed
as a result of the war.
The “Fair Price Agreement”
In April 1979, Ammareh traveled to the United States, where
he stayed with petitioners. Ammareh asked petitioner to sell the
remainder of the business to him or to buy him out. On April 21,
1979, petitioner handwrote the following statement in Persian (as
translated):
On April 21, 1979, it was resolved between the
undersigned that I, Ferydoun Ahadpour, sell all my 50
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