Victor M. Bello - Page 6




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          expectation that additional future funding would be secured from            
          the Bank of Development, a Brazilian governmental agency then               
          helping private investors develop various tourism-industry-                 
          related projects in Salvador.                                               
               In mid-1988, the 12-cabana complex was temporarily closed              
          for business due to the disruption caused by the expansion                  
          project.  The complex was again reopened for business by 1989.              
               Because of a downturn in the Brazilian economy,1 petitioner            
          never received the Brazilian governmental funding he had expected           
          for the hotel expansion.  Although he then attempted to obtain              
          financing from other sources, including certain sources in the              
          United States, his efforts were unsuccessful.  In 1990,                     
          petitioner was no longer able personally to finance construction            
          of the hotel expansion or the operation of the 12-cabana complex.           
          Construction on the hotel expansion ceased sometime in 1990.                
          When construction was halted, only the skeleton of one of the               
          planned wings (the concrete and steel "Building A" located east             
          of the 12-cabana complex) had been erected.  In 1990, the 12-               
          cabana complex was also closed for business.                                
               From 1986 through 1990, petitioner reported gross receipts,            


               1When the March 1988 study on the hotel expansion was                  
          issued, petitioner had hoped to finance approximately 51 percent            
          of the project’s total cost by obtaining a 6-year loan from the             
          Bank of Development.  He originally had obtained the study, in              
          part, to help him in procuring such Brazilian governmental                  
          funding.                                                                    





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