Joao Montoro and Neuza Paula - Page 25

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               Respondent contends that petitioner-husband told Davis                 
          during the examination that wire transfers to petitioners' bank             
          accounts were from Brazilian business customers who wired sales             
          revenue to him.  Petitioner-husband later told Davis and                    
          testified that other people, including his sister, sent him money           
          from Brazil.                                                                
               Petitioner-husband testified that only petitioners had                 
          access to their safe in Brazil.  Respondent contends that                   
          petitioner-husband told Davis that wire transfers from MTB,                 
          Cayman Islands, were sales revenue from a customer (MTB), but               
          later told her and testified that three or four people, including           
          his secretary and his sister, wired him money from Brazil.  He              
          told Davis that his sister asked a person with an account outside           
          of Brazil to wire the money.                                                
               We believe that petitioner-husband satisfactorily explained            
          the wire transfers to petitioners' U.S. accounts.  Petitioner-              
          husband credibly testified that, as his business started to grow            
          and he needed more money to invest in it, he had several people,            
          including his sister and his secretary, wire money from Brazil to           
          petitioners' U.S. accounts.  He testified that, on some of his              
          trips to Brazil, he took money from the safe, gave it to his                
          secretary to pay expenses such as Social Security, and she wired            
          him the balance.  He also testified that MTB is a bank and denied           
          telling Davis that it was a customer.  He also testified that he            
          collected a few thousand dollars from two customers in Brazil.              




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Last modified: May 25, 2011