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furnishings and fixtures, and asked that the letter be added to
schedule A of the Declaration of Trust. The jewelry Robert
bought and transferred to the Riago Trust during 1982, included a
$3,780 gold bracelet, $1,600 gold and diamond earrings, a $7,050
diamond ring, and a $7,950 Rolex watch.
On October 20, 1983, about 1-2 months after petitioners and
their daughters moved from Ohio to Florida, the Declaration of
Trust for the Riago Trust was filed in Florida. On December 19,
1983, petitioners amended the Riago Trust's Declaration of Trust.
Among other changes, the amendment purported to make the Riago
Trust irrevocable. A commentary and attachment to the Riago
Trust's financial statement, signed by Robert on October 23,
1984, lists the trust assets as having a total value of
$10,194,060.08, liabilities of $367,336.49, and a net value of
$9,826,723.59. The listed assets include the following: A 1981
Rolls Royce, a 1979 Cadillac Eldorado, a 1954 Corvette, a 1984
Chrysler LeBaron, a Russian Sable coat and jewelry valued at
$67,000, a $270,000 home, a $110,000 home, a $300,000 home, a
$361,000 interest in a Saberliner Jet, and a $25,000 interest in
Lincoln American Securities, Inc. Robert bought the Corvette,
Cadillac, and sable coat. Monica wore the sable coat.
On August 20, 1983, Robert, as trustee for the Riago Trust,
bought two homes in Edgewater, Florida. Petitioners and their
daughters lived in one of the homes. On February 13, 1984,
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