Victor M. Bello - Page 4




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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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