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B. Exhibits 1-P, 13-P, 14-P, and 16-P
Exhibit 1-P is the declaration with the Ministry of Justice
of the Islamic Republic of Iran to discharge Ammareh’s powers of
attorney.10 Respondent objected on the basis of hearsay.
Exhibit 16-P is the letter petitioner received from the
Revolutionary Moslem Group in Iran to which respondent objected
on the basis of authenticity, hearsay, and completeness.
Exhibits 13-P and 14-P are the documents sent to petitioner
by his Iranian attorney in 1980 to which respondent objected on
the basis of completeness, hearsay, and authenticity.
We overrule respondent’s objections and admit these
documents into evidence.
Petitioners’ Contentions
Petitioners contend that they should be allowed a bad debt
deduction of $8 million that arose from the sale of GMS in 1976.
Apparently, petitioners argue that GMS was a corporate entity
that was simply an empty shell for estate planning purposes to
which petitioner would eventually transfer his assets and
ultimately distribute them upon his death.
Petitioners also contend that the Statement of Account
memorialized the 1976 agreement and that they made efforts to
10 Respondent also charged that Ammareh’s signature on this
document appeared to be a forgery. The parties agreed to have
the document examined by an expert, though no followup report was
ever submitted. Accordingly, we reject respondent’s charges.
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