- 12 - 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.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011