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horses. She did not participate in these activities, except to
occasionally visit Sheldon's garment business showroom or a race
track where one of Sheldon's horses was running. She did not
participate in the decision-making. Sheldon had several bank
accounts in his own name, but Nancy did not have access to the
records for these bank accounts. Until 1985, Sheldon did not
tell Nancy about the grossly erroneous item, or the State Coal
investment that produced that item. Also, Sheldon did not tell
Nancy of the $81,054.77 tax refund check that he received on
account of the grossly erroneous item, or that he deposited the
check in one of his bank accounts, or that he made withdrawals
that exceeded the deposited amount within about 2� weeks after
the deposit. She did not learn of this until after Sheldon died.
Thus, as to most business and major investment matters, Sheldon
neither hid nor volunteered what was happening, but clearly he
hid the State Coal investment and its tax aftermath. There was
no lavish or unusual expenditure or large unexplained increase in
the Silverman's standard of living at, or after, or in connection
with, the State Coal investment or the tax refunds. Unlike
Sheldon's garment industry and horse racing activities, State
Coal did not have any showrooms to visit or horse races to watch.
Apart from the 1981 tax return itself, we are satisfied on
the record in the instant case that nothing occurred that should
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