4
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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