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experience. She also is knowledgeable on, and has experience
with, her personal income tax returns which are filed under
penalties of perjury.
We conclude that this factor evidences fraud.
c. Omission or Concealment of Assets
Respondent argues that the estate omitted and concealed
assets, and that these actions evidence fraud. Respondent points
to the fact that the estate failed to report a large amount of
assets. The estate concedes that certain items were wrongly
omitted from the decedent's estate tax return, but argues that
the estate did not fail to report these items intending to
conceal them. The estate contends that the items seized from the
safe deposit boxes were given to the coexecutors in September
1991, and that the coexecutors believed that the assets were not
includable in the estate.
We agree with respondent that the presence of unreported
assets in this case is evidence of fraud. The decedent had
advised Ms. Gonzalez of his holdings at a point in time that was
close to his death, and he had introduced her to all of his
advisers. The coexecutors simply did not include all of the
decedent's assets in his gross estate. Even if we were to assume
arguendo (and contrary to the record) that the decedent gave some
items to the coexecutors in September 1991, this does not explain
why several other items were omitted from the decedent's estate
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