Victor M. Bello - Page 3




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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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