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medical treatment for Janet, and they lived in Chicago, Illinois,
for approximately 11 years prior to trial. Sometime during 1993,
or prior thereto, petitioners determined that medical treatment
was too costly in the United States, and Janet returned to Mexico
for treatment. Janet lived with petitioner's mother, Altagracia
Figueroa, and father, Jacinto Olvera Camacho. Petitioner's
parents live in a rented two-bedroom home in the city of
Cuernavaca, in Morelos, Mexico. In addition to Janet,
petitioner's sister, Zulma Olvera, resided in the home.
Petitioner's father worked periodically, doing electrical or
plumbing work, but he did not work on a regular basis. By
petitioner's estimates, his parents' annual expenditures for
rent, utilities, and food averaged approximately $6,390 during
the years in issue.
In June 1993 Felicitas Olvera (Mrs. Olvera) and Illiana
returned to Mexico to care for Janet because petitioner's mother
became ill. Mrs. Olvera and Illiana stayed with Mrs. Olvera's
parents. Janet remained with petitioner's parents.
During the years in issue, petitioner wired money to various
relatives in Mexico to help support his parents and his sister
Zulma Olvera, to pay for Janet's care, and to support Mrs.
Olvera, Janet, and Illiana. Petitioner wired funds at least 12
times in 1993 and at least 6 times in 1994, transferring amounts
totaling $3,510 and $2,400 in 1993 and 1994, respectively. Of
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