Joao Montoro and Neuza Paula - Page 21

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          poor records, did not show how much cash they had on December 31,           
          1989, and gave inconsistent estimates of their cash on hand on              
          that date.  Respondent points out that petitioner-husband                   
          initially told Davis that he had less than $500 in cash at the              
          beginning and end of 1990.  We believe that petitioner-husband's            
          answer was consistent because he did not think Davis intended               
          cash on hand to include money he had in Brazil.                             
               Petitioner-husband initially told Davis that he brought no             
          more than $8,000 from Brazil two or three times a year.  However,           
          he made that statement to Davis before he told her about the                
          significant amount of funds petitioners had in Brazil at the end            
          of 1989.  We are convinced that petitioner-husband brought more             
          than $8,000 twice a year in 1990 and 1991.                                  
               As discussed above, we believe much of petitioner-husband's            
          testimony about petitioners' cash on hand in 1990.                          
               5.   Values Stated on Petitioners' Brazilian Tax Returns               
               Petitioners contend that their 1986 Brazilian tax return               
          shows that they had $534,160 (in U.S. dollars) in cash on                   
          December 31, 1986.  We disagree.  Petitioners reported on their             
          1986 Brazilian return that they had Cr$ 4,753,690 ($326,939) in             
          cash and the apartment in Mongagua worth Cr$ 420,000 ($28,886),             
          for a total of $355,825.                                                    
               Petitioner-husband testified that petitioners had $328,975             
          in cash and $209,244 for the "difference of the sales" in                   
          December 1986, which they contend is supported by deeds showing             




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