23
Madre Maria Santa Margarida house for $135,667 as reported on
their 1986 Brazilian return.
6. Petitioners' Deposits from Nontaxable Sources
a. Petitioners' Contentions
Petitioners contend that petitioner-husband brought $8,000
back from a trip to Brazil on July 17, 1991, and deposited it 2
days later. We disagree. The July 19, 1991, deposit was made by
wire transfer. We have not included this amount as a nontaxable
source of funds.
Petitioners contend that petitioner-husband made a $20,000
deposit to one of his joint accounts with Mr. Simoes on September
25, 1990, from nontaxable funds. We disagree. Petitioner-
husband told Davis that Mr. Simoes gave him $20,000 to buy parts
or to pay Underwriters' Laboratories. In contrast, petitioner-
husband testified that Mr. Simoes gave him the money to buy
samples, that Mr. Simoes lent him the $20,000, and that the money
was to pay Mr. Simoes' expenses while he was in the United
States. Petitioner-husband's explanations are inconsistent, and
we have not included this amount in petitioners' nontaxable
sources of funds.
Petitioners contend that a $29,307 wire transfer from the
Cayman Islands to one of their accounts in August 1991 was money
Mr. Arnaldo was holding for petitioner-husband in Brazil. We
disagree because Mr. Arnaldo's name is not on the record of the
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