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Petitioner was not engaged in the sale of stock as a trade
or business in 1979. Petitioner owned a rental apartment near
London that he had received as a gift. He never lived in that
apartment.
C. Events in the 1980s
1. Filing of Petitioner’s Family’s Expropriation Claim
Petitioner and his family learned of the expropriation in
1980. On May 15, 1980, petitioner’s father, on behalf of his
immediate family, filed with the Office of Foreign Assets Control
of the United States Department of the Treasury a claim for the
expropriated property (Census of Claims by United States Persons
Against Iran). In it, petitioner’s father claimed expropriation
losses of $113,530,000, including stock which he valued at
$11,580,000; the Customs Administration Building which he valued
at $20 million; other real property which he valued at $10.45
million; loans which he valued at $1.5 million; and tangible
personal property which he valued at $70 million. Petitioner
signed the claim. In the claim, petitioner’s father stated that
the date of loss was June or July 1979. Petitioner’s family
prepared the form from memory. None of the property listed in
the claim was ever connected with a trade or business in the
United States.
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