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Freidus authority to invest on her behalf or have approved
transactions entered into on her behalf had she not wished him to
do so. Overall, petitioner did not behave like a person needing
protection from the spending habits of her husband.
Moreover, a substantial amount of proceeds from the sale of
the Golden Maharaja diamond and the sale of Picasso ceramics that
were wired into the Pierpont Account were disbursed to
petitioner's corporate accounts. For instance, petitioner
disbursed $555,000 to Ivory Land upon the sale of the Golden
Maharaja in March 1990. Petitioner also disbursed a total of
$223,125 to Ivory Land upon the sale of the 35 Picasso ceramics
in June of 1990. On December 27, 1990, when petitioner sold 187
Picasso ceramic pieces for $1,943,330, petitioner directed Burns
to transfer $340,000 to the Ivory Land account. Transferring
these amounts from the safety of the secret Pierpont Accounts
into the Ivory Land corporate account exposed the transferred
amounts to the blank corporate checks in Mr. Freidus' possession
and is therefore inconsistent with petitioner's stated purpose of
hiding assets from Mr. Freidus.
Due to petitioner's inconsistent behavior, we conclude that
protection from the consequences of voluntarily giving Mr.
Freidus blank signed checks drawn upon her corporate bank
accounts was not a purpose of the Pierpont Account. We further
conclude that petitioner's inconsistent and implausible
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