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to the Statement of Account and provided Ammareh 1 month in which
to pay his debt to petitioner. If payment was not made, then Mr.
Izadi would take legal action. Ammareh responded to this notice
and stated that he had owned 50 percent of GMS and that
petitioner sold the remaining 50 percent to him (which was in the
name of petitioner and his sons). Ammareh also stated that he
had paid petitioner $130,000 for the 50 percent he sold in 1979.
Ammareh finally stated that the Statement of Account was drawn up
so that petitioner could “escape the taxes of the U.S.
government”.7
On April 25, 1989, Fariborz sent a letter to petitioner
stating that they had to file the claim quickly since the 10-year
period of limitation was running and it has been almost 10 years
since the Statement of Account was signed (April 30, 1979).
Petitioners believed that there was a 10-year period of
limitations for the filing of a lawsuit in pursuit of an unpaid
debt. Fariborz paid the attorney's fees and requested
reimbursement from petitioner. Fariborz also detailed what other
attorney's fees and filing fees could be incurred if the suit was
pursued.
7 Another translation of this document translates this
phrase as “to present to the authorities”. Respondent does not
agree with this translation.
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