Ella Freidus - Page 24

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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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