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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