Faramarz and Mitra Elghanian - Page 6

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          States.  After graduate school, petitioner told Steven Kumin                
          (Kumin), a friend of his who lived in the Boston area, that                 
          petitioner intended to reside in the United States.                         
               3.   The Customs Administration Building in Tehran, Iran               
               On a date not specified in the record, petitioner’s father             
          paid about $2 million to buy land in Tehran, Iran, on which he              
          intended to build his personal residence.  At a time not                    
          specified in the record, petitioner’s father arranged to have the           
          Customs Administration Building constructed on that site.                   
          Petitioner’s parents owned the land on which it was to be built.            
               The Customs Administration Building had 3 underground                  
          parking levels, about 25 retail stores, and 3 office towers which           
          were 11 or 12 stories high.  The building occupied about an acre            
          of land.  It cost about $15 million to build the Customs                    
          Administration Building and another $1.5 to $2 million for tenant           
          improvements.  The Iranian Department of Taxation and Customs               
          occupied the Customs Administration Building.                               
               Petitioner conveyed an interest in the building (about 6               
          meters by 14 meters, not otherwise described in the record) to              
          the regional electrical company for a price not stated in the               
          record on a date not clear from the record.                                 











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