Ferydoun Ahadpour, a.k.a, F. Ahadpour, And Doris Ahadpour - Page 12




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          whether this document was sent with the forms mentioned above.              
          Attached to the Tax Shelter Questionnaire is the following                  
          statement:                                                                  
               On April 30, 1979, taxpayer sold his business, Gulf Marine             
               Services, a construction and salvage company operating                 
               solely in the country of Iran, for $8,000,000 to an Iranian.           
               * * * Two million dollars of said purchase price was                   
               deposited into a bank in Iran, and the remaining balance of            
               six million dollars was to be paid in intervals agreed upon            
               between the parties in the future, with all such future                
               payments to be deposited in a bank in Iran to the taxpayer’s           
               account.                                                               
               No payments since the date of sale have been paid, although            
               taxpayer has made numerous attempts to make collections on             
               this note.  However, due to the political and economic                 
               situation in Iran, it was evident in 1985 that no further              
               payments on this note will ever be received by the taxpayer,           
               nor will he have access to the funds previously deposited in           
               the Iranian bank.                                                      
               Consequently, the taxpayer’s loss in the business bad debt             
               will decrease his personal income and no Federal income tax            
               is expected to be owed for 1985.                                       
               On April 1, 1986, Ms. Kauls sent a copy of the Khossravi               
          appraisal to the IRS.  On the basis of this appraisal, Ms. Kauls            
          stated that petitioners were planning on claiming a loss of $1.1            
          million on their 1985 income tax return.                                    
               In a letter to petitioners dated May 2, 1986, Ms. Kauls                
          updated petitioners on the status of their 1985 return and                  
          requested further information.  Ms. Kauls additionally stated:              
               We will continue to check on the deductibility of the loss             
               of your business in Iran (Gulf Marine Services) on your 1985           
               tax return.  However, as we discussed, you will probably not           
               be allowed the deduction due to the fact that it appears you           
               sold the business prior to your leaving Iran and becoming a            
               U.S. resident.                                                         






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