Joao Montoro and Neuza Paula - Page 3

                                          3                                           
               (4)  Whether certain exhibits offered by respondent to                 
          impeach the testimony of petitioner-husband are admissible.  We             
          hold that they are not.                                                     
               References to petitioner-husband are to Joao Montoro Paula.            
          References to petitioner-wife are to Nueza Paula.  Section                  
          references are to the Internal Revenue Code in effect for the               
          years in issue.  Unless otherwise indicated, rule references are            
          to the Tax Court Rules of Practice and Procedure, and references            
          to income tax returns are to United States (Federal) income tax             
          returns.                                                                    
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          A.   Petitioners                                                            
               Petitioners lived in Raleigh, North Carolina, when they                
          filed the petition in this case.  Petitioner-husband was born and           
          raised in Brazil.  He graduated from college there and has                  
          degrees in chemical engineering and business administration.                
          Sometime before 1972, petitioner-husband worked for Ford Motor              
          Co. in Brazil for 6 years and was promoted to a management                  
          position.                                                                   
               Petitioners have three sons:  Luiz, born in 1970; Ricardo,             
          born in 1972; and Leandro, born in 1975.                                    
               Petitioners have had an apartment in Brazil from 1984 until            
          the time of trial.  Petitioners were resident aliens of the                 
          United States during the years in issue.                                    




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