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On March 14, 1990, petitioner negotiated the sale of her 65-
carat diamond, the Golden Maharajah. Petitioner had originally
purchased the Golden Maharajah for $30,000, prior to her marriage
to Mr. Freidus. She sold the Golden Maharajah for $1.3 million.
Burns deposited the $1.3 million into his firm's client escrow
account. He then paid $640,280 to various third parties,
$555,000 of which was disbursed to the account of Ivory Land, and
transferred $654,720 into petitioner's Pierpont Account. Mr.
Freidus was not involved in the sale of the Golden Maharajah.
Petitioner sold 35 Picasso ceramic pieces on June 26, 1990,
for $500,000. Burns deposited the $500,000 into his firm's
client escrow account. Burns disbursed these funds in accordance
with petitioner's instructions to various third parties,
including Sotheby's, Phillips International Corporation, and
Ivory Land. Mr. Freidus gave no directions regarding the sale of
the Picasso ceramics or the distribution of the sale proceeds.
On December 27, 1990, petitioner sold 187 Picasso ceramic
pieces for $1,943,330. Once again, the sale proceeds were
deposited into the client escrow account of Burns' law firm.
Petitioner directed Burns to deposit $1,000,000 into petitioner's
Pierpont Account and to transfer $340,000 to Ivory Land and
$546,000 to Sotheby's Financial Services.
Petitioner purchased a number of art works by using personal
checks, charge cards, and loan proceeds from Sotheby's. The
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