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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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