-7-
million of sales which it had recently made to the decedent, and
it informed respondent that those receipts did not necessarily
reflect all of the sales which it had made to the decedent.
Respondent’s determination of the estate’s unreported assets also
was supported by respondent’s examination of canceled checks of
the decedent payable primarily to Mamiye and Lloyds, respondent’s
comparison of the items on the receipts furnished by Mamiye and
Lloyds with the assets described by the individuals with whom
respondent conversed, and respondent’s seizure from the Trust’s
safe deposit box at Union Bank (safe deposit box) of unreported
assets consisting of various bullion coins, 41 gold coins, 14
loose gemstones, and 11 items of jewelry.
Following our trial of this case and our detailed review of
the record, we agreed with respondent that the estate had failed
to report a significant amount of assets. The estate conceded
that this amount was a little over $1 million. We were persuaded
that the amount was much greater. We also were persuaded,
however, that this amount was less than the $14 million
determined by respondent. We proceeded to make an approximation
of the fair market value of assets omitted from the taxable
estate, recognizing that valuation is not an exact science and
that the task before us was difficult in that the coexecutors had
concealed information and assets from their accountants,
respondent, and this Court.
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