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Petitioner-husband credibly testified that $58,969 of the
1991 wire transfers (including $50,500 from the Cayman Islands)
to petitioners' bank accounts were from his own money in Brazil.
His testimony is consistent with the documentary evidence. We
have found that other wire transfers were from taxable sources.
On March 29, 1994, petitioner-husband told Davis that he had
obtained the funds for a $6,400 deposit in December 1990 from his
funds in Brazil on a November 16, 1990, trip. In contrast, he
testified that the deposit resulted from a bank-to-bank transfer.
Bank records corroborate his testimony; there was a $6,400
withdrawal from account 157460395 on December 3, 1990, and a
$6,400 deposit to account 6269-258236 on December 3, 1990.
Respondent contends that petitioners' deposits to their
accounts were not made from cash petitioner-husband brought from
Brazil because petitioner-husband or petitioner-wife waited up to
1 month after petitioner-husband returned to the United States to
deposit money in one of their accounts. We disagree for the most
part. Petitioner-husband sometimes kept the money in a safe in
his Raleigh office before he deposited it in his non-interest
bearing checking accounts. To the extent that petitioner-husband
did not convince us that deposits were from nontaxable sources,
we did not include those deposits as a nontaxable source of
funds.
Respondent contends that the fact that petitioner-husband
used the 108 Rua Luiz Gama address as his address on his 1989
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