21 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 showingPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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