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and Rio de Janeiro. In the mid-1960's, the State of Bahia began
to promote the development of a tourism industry in Salvador. At
some point, an international airport was constructed in Salvador.
From 1969 through 1986, the number of domestic and international
tourists annually visiting Salvador increased dramatically. By
1986, an estimated 1.3 million tourists annually visited
Salvador, making it the third most visited city in Brazil after
Rio de Janeiro and Sao Paulo. Numerous establishments in
Salvador offer hotel and other lodging accommodations to
visitors. These establishments range from five-star hotels to
pensions and campgrounds.
During his 1984 visit to the Flamingo Beaches, petitioner
was impressed by the scenic beauty and pristine nature of the
area. He examined certain undeveloped lots offered for sale in a
recently subdivided large tract of land in the Flamingo Beaches,
and he purchased two of those lots to build a summer home.
However, he later decided to build a small hotel. From 1984
through 1986, petitioner purchased a total of 17 contiguous lots
in that same tract for the purpose of building his hotel.
Since petitioner resided and conducted his medical practice
in the United States, he arranged to have another individual in
Brazil supervise the construction of the complex and manage it.
Pursuant to this arrangement, petitioner agreed to finance the
construction and operation of the hotel but promised to give this
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