Ramzy M. and Lena Kopty - Page 17




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         He was briefly treated in the emergency room of the American                 
         Hospital in Dubai on November 29, 1999, and approximately one                
         week later, on December 6, 1999, he returned to the hospital to              
         engage in a treadmill test.  The interpretation of that test                 
         states the following:                                                        
              Exercise EKG positive for Ischemie by EKG criteria.  No                 
              exercise induced chest pains or arrhythmia.  Normal BP                  
              response to exercise.  Impaired functional capacity for                 
              patient’s age achieving 10.6 METS.                                      
              Subsequently, Mr. Kopty was admitted to the American                    
         Hospital in Dubai on March 3, 2000, with the symptoms of a heart             
         attack.  Approximately 2 weeks later he was transported to the               
         Universite Catholique De Louvain Cliniques Universitaires Saint-             
         Luc, a hospital in Belgium, where he underwent coronary bypass               
         and mitral valve repair on March 25, 2000.  Mr. Kopty was                    
         released on April 10, 2000, but was readmitted from time to time             
         for further treatment through the end of June 2000.                          
              The medical records submitted by petitioners make it clear              
         that Mr. Kopty’s heart attack and related medical problems                   
         between March and June of 2000 were serious.  Mr. Kopty’s                    
         treating physician in Belgium wrote on July 29, 2000, “since                 
         March 3, 2000 Mr. Kopty had to stop his professional activities.             
         It seems obvious that these activities will have to be strongly              
         reduced in the future.”                                                      
              In November of 2004, after the Internal Revenue Service                 
         audited petitioners’ returns for 1999 and 2000 and issued the                






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