Joao Montoro and Neuza Paula - Page 4

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          B.   1986 Revaluation of Brazilian Currency                                 
               On February 28, 1986, Brazil significantly revalued the                
          cruzeiro (Cr$).  Beginning February 28, 1986, the Brazilian                 
          currency was the cruzado (Cz$).  One cruzado equals 1,000                   
          cruzeiros.2  "Brazilian Cruzeiro/Cruzado," 1986-1987 World                  
          Currency Yearbook, 242-249 (Philip P. Cowitt, ed. 1989).  The               
          exchange rate was Cr$ 13,020 per U.S. dollar in February 1986 and           
          Cr$ 13.84 per U.S. dollar in March 1986.                                    
          C.   Petitioner-Husband's IBM Employment                                    
               In 1972, petitioner-husband began to work for IBM-Brazil in            
          Campinas, Sao Paulo, Brazil.  He worked for IBM for 18 years in             
          Brazil and the United States.  In 1987, he began to work for IBM            
          in Raleigh, North Carolina.  In late 1989 or early 1990, he                 
          returned briefly to Brazil to work for IBM-Brazil.  He soon took            
          a leave of absence from IBM and returned to the United States.              
               IBM wanted petitioner-husband to work in Brazil.  He                   
          resigned from IBM in January 1991 because his family wanted to              
          stay in the United States.                                                  
          D.   Petitioners' Assets in Brazil in 1986                                  

               2 The average official exchange rate was $1 to Cr$ 1841.50             
          for 1984, and $1 to Cr$ 6205.10 for 1985.  Federal Reserve                  
          Bulletin, International Statistics (Sept. 1986; Mar. 1987),                 
          Foreign Exchange Rates.  On Feb. 28, 1986, the official exchange            
          rate of cruzados to U.S. dollars was $1 to Cz$ 13.84.  See                  
          Norwest Corp. v. Commissioner, 108 T.C. __ n. 19 (Apr. 30, 1997).           
          The parties stipulated that the exchange rates for 1986 were as             
          listed in the Federal Reserve Bulletin:  Jan. Cr$ 11345.26; Feb.            
          Cr$ 13020.00; Mar.-Sept. Cr$ 13.84 (after the currency reform);             
          Oct. Cr$ 13.98; Nov. Cr$ 14.10; and Dec. Cr$ 14.54.                         




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