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On February 24, 1995, respondent, pursuant to a jeopardy
assessment, seized assets located in two safe deposit boxes that
were registered in the name of the Trust. The boxes were located
respectively at First Interstate Bank and Union Bank in Encino,
California. The safe deposit box at First Interstate Bank
contained gold coins which belonged to the Trust and which, with
one exception, were the 36 additional coins reported on the
decedent's estate tax return. The safe deposit box at Union Bank
contained assets that were not reported on the decedent's return.
These unreported assets included gold and silver coins and a
portion of the jewelry and gems in issue. The coexecutors
reported on the decedent's estate tax return that he neither
owned nor had access to a safe deposit box at the time of his
death. In addition to the two safe deposit boxes at the banks,
the decedent had a safe in his house. The coexecutors knew of
the existence and location of the safe and safe deposit boxes,
and they knew that the decedent had access to all three "safes".
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