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wire transfer. We have not included this amount in petitioners'
nontaxable sources of funds.
b. Respondent's Contentions
Respondent contends that the inheritance check petitioner-
husband received from his father was worth about $120, using the
August 1986 exchange rate of Cz$ 13.84. We disagree.
Respondent's contention about the value of petitioner-husband's
inheritance is contrary to the stipulated exchange rates for
dollars and cruzeiros in August 1986.
Respondent points out that petitioner-husband told Davis
that there were no records of the inheritance check he received
from his father, but at trial he offered into evidence a copy of
the check for Cr$ 1,660,800 ($120,000). We admitted the check
because petitioner-husband had given respondent the number of the
check about a month before trial.
Respondent points out that petitioner-husband told Davis
that he was uncertain whether he had more or less than $10,000 in
the safe. Respondent contends that this is inconsistent with
petitioner-husband's later claim that he kept a large amount of
cash in the safe. Respondent's point seeks to make something out
of nothing. We believe that petitioner-husband kept money in the
safe in Brazil but did not initially tell Davis the amount.
Petitioner-husband wrote to Davis in March 1994 and revised his
estimate of petitioners' cash on hand to include funds from the
sale of petitioners' Brazilian assets.
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