6
brother. Petitioner-husband reported the sale of these assets on
the Brazilian income tax return he filed for 1986.4 In signing
the 1986 Brazilian return, petitioner-husband attested to its
truth. Petitioners reported that, at the end of 1986, their
Brazilian assets (consisting primarily of cash) totaled Cr$
5,173,690 ($355,825). Petitioners kept the cash from the sale of
these assets in a safe in Brazil.
E. Petitioners' Trips to and Movement of Cash From Brazil
In 1990, petitioner-husband traveled to Brazil four times.
He returned to the United States from the first trip on March 16.
Petitioners' son, Leandro, played soccer for the Raleigh Flyers.
In the summer of 1990, petitioner-husband took the team to
Brazil. He returned to the United States on July 5 or 6, 1990.
He returned from his next trips on September 19 and November 16.
He brought cash from their safe on each of these trips.
Petitioners used this money to pay their rent and other living
expenses, their son's college tuition, and to provide funds for
petitioner-husband's business, International Best Buys (discussed
at par. F below).
4 Brazilian law did not require petitioner-wife to sign the
Brazilian tax return.
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