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All section references are to the Internal Revenue Code as
amended and in effect during the years in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are found
accordingly. The stipulation of facts and accompanying exhibits
are incorporated by this reference.
Petitioner resided in Chagrin Falls, Ohio, when he filed his
petition. Petitioner was born in Nicaragua and left there in
1964 to study medicine in Brazil. In 1972, petitioner emigrated
to the United States, where he has been a practicing
ophthalmologist.
Villa del Mar Hotel Venture
During 1984, petitioner returned to Brazil on a trip with a
group of ophthalmologists studying tropical ophthalmology. While
on that trip, petitioner visited the Flamingo Beaches area of the
City of Salvador in the State of Bahia. Salvador lies on the
Atlantic Ocean and is located approximately 1,656 kilometers
northeast of Rio de Janeiro. Salvador was the first city founded
in Brazil and served as Brazil’s first capital. It contains a
number of cultural and historical sites, including churches,
forts, mansions, and palaces. In addition, the area enjoys a
mild climate and has many beaches along the Atlantic coastline.
In 1959, a major highway was completed linking the State of Bahia
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