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the purchase and sale of petitioners' real property in Brazil.
Petitioner-husband did not define the phrase the "difference of
the sales". As discussed below, we find that petitioners had
$326,939 in cash in December 1989.
Petitioner-husband testified that he sold the Rua Jose Jorge
Farah property for $150,000 and the house at Rua Madre Maria
Santa Margarida for $140,000. Respondent points out that these
amounts are inconsistent with the amounts petitioners reported on
their 1986 Brazilian return. We agree. Petitioner-husband
reported that he sold the Rua Jose Jorge Farah property for Cr$
1,660,000 ($119,942) and the Rua Madre Maria Santa Margarida
house for Cr$ 1,972,600 ($135,667) on petitioners' 1986 Brazilian
return.
Statements in a U.S. Federal tax return are admissions under
Rule 801(d)(2) of the Federal Rules of Evidence and will not be
overcome without cogent evidence that they are wrong. Waring v.
Commissioner, 412 F.2d 800, 801 (3d Cir. 1969), affg. per curiam
T.C. Memo. 1968-126; Estate of Hall v. Commissioner, 92 T.C. 312,
337-338 (1989); Lare v. Commissioner, 62 T.C. 739, 750 (1974),
affd. without published opinion 521 F.2d 1399 (3d Cir. 1975). In
signing the Brazilian return, petitioner-husband attested to its
truth. We believe it is appropriate to apply this doctrine to
petitioners' Brazilian returns. Thus, we find that petitioners
sold the Rua Jose Jorge Farah property for $119,942 and the Rua
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