27
adjusted Brazilian tax return and 1991 Brazilian tax return shows
that petitioners did not sell that house in September 1986. We
disagree; we give more weight to the fact that petitioners
reported the sale of and paid tax on the Rua Luiz Gama property
on their 1986 Brazilian tax return than we do to the fact that
petitioner-husband used that address on his 1989 and 1991
Brazilian returns, filed when petitioners were no longer living
in Brazil.
Respondent argues that petitioners did not have a
substantial amount of funds in 1990 because petitioner-husband
testified6 that he spent all of the money he brought from Brazil
to the United States accompanying the Raleigh Flyers soccer team
to tournaments in the United States for 5 years. We disagree.
We do not believe that petitioner-husband meant that he actually
spent all of his money following the soccer team.
c. Conclusion
Petitioners owned and sold real property and other assets in
Brazil in 1986, and petitioner-husband brought cash into the
United States when he returned from trips to Brazil. About half
of petitioners' deposits in 1990 and 1991 came from the cash that
6 Petitioner-husband testified as follows:
Q * * * why did you take a soccer team to Brazil?
A * * * I was following since 19-- five years, that I was
following that team, you know, expending all the money that I
brought from Brazil in hotels, in tournaments, here in the United
States, you know, following * * * [those] boys.
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