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tax return. This also does not explain the fact that the estate
attempted to conceal the safe deposit boxes from the Government
by reporting on the decedent's estate tax return that he neither
owned nor had access to a safe deposit box when he died. The
coexecutors knew that the decedent owned the safe deposit boxes
at the banks, or at least that he had access to them. The
coexecutors also knew that the decedent owned and had access to
the safe in his house.
We conclude that this factor evidences fraud.
d. Failure To Cooperate
Respondent argues that fraud is seen from Ms. Gonzalez'
failure to include any diamonds in the estate, and her failure to
disclose all of the decedent's records revealing purchases of
jewelry, gems, art, and other artifacts when originally
requested.
We agree. Ms. Gonzalez failed initially to provide
respondent with all of the decedent's canceled checks which
evidenced the purchase of jewelry, gems, art, and other
artifacts. Ms. Bates also asked Ms. Gonzalez whether the
decedent owned any jewelry or diamonds when he died, and Ms.
Gonzalez answered in the negative.
We conclude that this factor evidences fraud.
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