- 3 -
petitioner and his associates purchased four business properties
in Iran for development. Petitioner invested substantial sums of
money for purchase of the properties and for improvements and
equipment. While the cost of the properties and improvements is
not entirely clear, petitioner asserts that the fair market value
of his one-third investment interest in the properties exceeded
one million dollars in 1994/1995.
In 1979 the Shah of Iran was deposed in a revolution. The
Ayatollah Khomeini was installed as the new leader of Iran.2 The
Iran-Iraq war commenced in 1981 and ended in approximately 1988.
About that time, petitioners and their children escaped from Iran
and gained political asylum in the United States.
There were dramatic changes in petitioner’s business after
the 1979 revolution and during the Iran-Iraq war. As a person of
Jewish faith, he was excluded from business opportunities with
any governmental units. Additionally, revolutionaries occupied
some of the land and improvements and also appropriated
equipment. With respect to one of the parcels of property in
Mobarak Abad (Tehran), persons began building homes on the land
in approximately 1981 and 1982. Petitioner and his associates
were unable to prevent the occupation or remove persons from the
2 A detailed account of the events in Iran is set forth in
Continental Ill. Corp. v. Commissioner, 94 T.C. 165 (1990);
Halliburton Co. v. Commissioner, 93 T.C. 758 (1989), affd. 946
F.2d 395 (5th Cir. 1991); and Moshrefzadeh-Sani v. Commissioner,
T.C. Memo. 1992-592.
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