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receipts and disbursements journals, the general ledger, work
papers, adjusting journal entries, canceled checks, bank
statements, and deposit slips for all accounts for 1990.
Petitioners gave her some of the bank statements, but did not
give her International's books and records. In November 1992,
Davis asked petitioners for their canceled checks from December
1, 1989, to January 31, 1991. Petitioner-husband told her that
he had destroyed them.
On November 4, 1992, Davis asked petitioner-husband how much
cash on hand he had. Davis did not specify whether "cash on
hand" included cash petitioners may still have had in Brazil.
Petitioner-husband did not understand it to include cash
petitioners had in Brazil. Petitioner-husband told Davis that he
had less than $500 in cash on hand at the beginning and end of
1990.
Petitioner-husband told Davis that he brought no more than
$8,000 each time he returned from Brazil, two or three times a
year.
On November 19, 1992, petitioner-husband told Davis that he
had kept money in a safe in a house in Brazil until he sold the
house in 1990. After he sold the house, he kept the safe
elsewhere in Brazil. Petitioner-husband initially told Davis
that he did not know whether he had more or less than $10,000 in
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