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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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