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return, and she secreted Mr. Leidman's $8.5 million appraisal
from Ms. Bates. Given the additional fact that Ms. Gonzalez and
the decedent had discussed his coin holdings at a time close to
his death, and that she had represented to the court in the
Superior litigation that the 191 coins were worth more than
$12 million, we find that Ms. Gonzalez was well aware that the
$3,467,575 total value reported on the return was wrong.
Third, the estate failed to report any value for the assets
in the safe deposit box at Union Bank, and, in an attempt to
conceal the existence of this box, the coexecutors stated on the
estate tax return that decedent did not own or have access to a
safe deposit box at the time of his death. In a further attempt
to conceal the existence of the safe deposit box at Union Bank,
the coexecutors failed to report the existence of the safe
deposit box at First Interstate Bank, choosing only to report a
value for 35 of the coins which were found therein.14 In yet
another attempt to conceal the contents of the safe deposit box
at Union Bank, Ms. Gonzalez falsely answered in the negative when
Ms. Bates asked her whether the decedent owned any jewelry or
diamonds when he died. The decedent did own jewelry and diamonds
14 The estate would have reported the existence of the safe
deposit box at First Interstate Bank by stating on the decedent's
estate tax return that he had access to a safe deposit box when
he died. Such a statement would most likely have led respondent
to investigate further the circumstances of the box, which could
have led respondent to discover the safe deposit box at Union
Bank.
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