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Fifth Amendment, attorney-client privilege, and the work-product
doctrine. At no time was petitioner denied access to her
records.
Subsequently, Mr. Freidus filed a petition under Chapter 7
of the Bankruptcy Code. On October 1, 1991, the Bankruptcy Court
entered an order directing that Mr. Freidus and petitioner be
deposed and that they produce numerous documents with respect to
their financial condition. Petitioner's counsel advised the
United States that petitioner would not submit to a deposition,
invoking her rights under the Fifth Amendment; the United States
did not depose petitioner. The Bankruptcy Court denied Mr.
Freidus a discharge of his Federal tax liabilities. Mr. Freidus
presently owes the Internal Revenue Service in excess of $21
million.
During the years in issue, petitioner traveled extensively.
She flew to auction houses in London. Petitioner and her husband
traveled to Tokyo, Japan, in early April 1988, at the request of
the Tokyo Metropolitan Art Museum to be present at the opening
ceremony of an exhibition entitled "The 1920's in Japan".
Petitioner also traveled to Russia and France to visit museums to
which she had lent paintings.
Petitioner now resides in an 8,000 square-foot home on 20
acres, with an in-ground pool, 4 fireplaces, 715 feet of
waterfront and a gazebo. At the time of trial, the house was on
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