Ferydoun Ahadpour, a.k.a, F. Ahadpour, And Doris Ahadpour - Page 23




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          collect on the debt.  Petitioners further contend that in 1989              
          the debt became worthless because the time within which to                  
          collect under the 10-year Iranian period of limitations on                  
          collection of this debt had expired.                                        
          Respondent’s Contentions                                                    
               Respondent first contends that no sale occurred giving rise            
          to any debt.  It is respondent’s view that petitioner disposed of           
          his interest in GMS and was fully paid by Ammareh.  According to            
          respondent, the alleged $8 million sale was rigged to enable                
          petitioner to avoid paying American taxes.  Respondent                      
          alternatively contends:                                                     
               a.  Any sale between petitioner and Ammareh took place in              
          1979 after petitioner had established residency in the United               
          States.  Therefore, petitioner failed to report any gain on the             
          sale and is limited (if there is a bad debt) to his basis in the            
          assets (which petitioner has not proven) or in his shares of                
          stock of GMS (at best $10,000).                                             
               b.  GMS was a corporation owned in part by petitioners and             
          any sale of the “business” to Ammareh was either at the corporate           
          level (i.e., GMS sold its business to Ammareh) or a sale of                 
          shares of stock from petitioner to Ammareh.                                 
               c.  Finally, respondent contends that petitioner has failed            
          to prove when any alleged debt became worthless, arguing that any           
          such debt had been worthless long before the years at issue.                







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