Joao Montoro and Neuza Paula - Page 7

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               In 1990, petitioners deposited $136,408 in nine bank                   
          accounts (eight in the United States and one in Brazil).  Of that           
          amount, the following is nontaxable:                                        
          Date   Check/currency    Amount deposited      Source of funds              
          4/12   travelers checks      $1,790          Mar. Brazil trip               
          4/24   Cr$ 1,679,225.87      30,531          Brazilian account              
          7/9   unknown       7,300                    July Brazil trip               
          7/11   currency          3,200               July Brazil trip               
          8/22   travelers checks       4,000          July Brazil trip               
          9/25   currency          1,007               Sept. Brazil trip              
          9/25   currency          1,436               Sept. Brazil trip              
          11/20  currency/trav. check    2,088         Nov. Brazil trip               
          11/20  currency          6,596               Nov. Brazil trip               
          12/3   currency5         6,400               Transfer                       
          12/3   check                 2,250           Cashed check for friend        
                    Total          $66,598                                            
               In 1991, petitioner-husband brought cash from their safe               
          after each of several trips to Brazil.  Petitioner-husband                  
          sometimes kept the cash he brought from Brazil in a safe in his             
          Raleigh office before he deposited it in petitioners' non-                  
          interest bearing checking accounts.  Petitioners deposited                  
          $396,905 in eight (seven U.S. and one Brazilian) bank accounts.             
          Of the $396,905, petitioners deposited Cr$ 14,651,647.28                    
          ($48,009) in the Bank of Itau in Brazil from their personal                 
          assets, and they made nontaxable deposits to U.S. bank accounts             
          as follows:                                                                 




               5 This deposit was a transfer from account 157460395.                  






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