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State inquiring whether a passport had ever been issued to a “Mrs.
Allen”. Again, the response was negative. Third, Mr. McGuire
reviewed Sloan's individual income tax returns filed before his
death; no spouse was ever listed. Further, Sloan's death
certificate stated that Sloan had died a widower. Accordingly, Mr.
McGuire concluded that there was no “Mrs. Allen”.
Mr. McGuire discovered that although David marked the “no” box
in response to the question of whether he had foreign bank accounts
during 1987 on Schedule B of his 1987 return, David had at least
three foreign bank accounts during 1987. (In his answer to
respondent's interrogatory No. 1 (which requested that David list
all domestic and foreign bank accounts, securities accounts, and
other financial accounts in which he had an interest or a signature
or other authority over at any time during 1987), David responded
by listing only two domestic accounts--the Morgan Guaranty checking
account and the Bank of Omaha account.) After being confronted
with certified transcripts indicating he had foreign accounts,
David admitted to the fact. (On his individual tax returns for
1988-91, David listed foreign bank accounts in the United Kingdom
and Switzerland but did not report any interest income from these
accounts.)
On the basis of his investigation, Mr. McGuire concluded that
David was the only individual who could possibly possess
information about Sloan's assets.
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