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Ms. Kauls met or had conversations with petitioners numerous
times during 1985 and 1986 with respect to the alleged sale of
GMS. According to notes that she took during these meetings and
conversations, at one point petitioners told Ms. Kauls that GMS
was not a corporation but a partnership and that Ammareh owned 10
percent. On another occasion, petitioners told Ms. Kauls that
Mrs. Ahadpour owned 20 percent. At one time, petitioner stated
that he sold the business in 1976, and on another occasion he
stated that the negotiations started in 1976, but the agreement
was not “drawn up or officially agreed upon until 1979.”
A bad debt deduction was not claimed on petitioners’ 1985
return.
Ms. Kauls left Johnson and Associates in 1988.
Collection Efforts
In 1987, petitioner asked his brother Fariborz Ahadpour
(Fariborz), a legal consultant in Iran, to initiate collection
efforts against Ammareh. It is not clear whether any collection
efforts took place during 1987 or 1988. In early 1989, Fariborz
hired Iranian attorney Naghi Izadi (Mr. Izadi) for petitioner.
Petitioner granted a power of attorney to Mr. Izadi to “sue in
civil and penal claims and cases”.
On April 10, 1989, Mr. Izadi filed a “Legal Notice” with the
Ministry of Justice of the Islamic Republic of Iran. This notice
was addressed to Ammareh. In his statement, Mr. Izadi referred
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