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discussing with the decedent the specifics of the assets which he
owned. Gonzalez, and to a lesser extent Polachek, became
knowledgeable of the specifics of the decedent’s vast wealth, and
Gonzalez in conjunction with Polachek deliberately undertook to
maximize their receipt of that wealth by, among other things,
undervaluing his assets and excluding assets from the taxable
estate.
Receipts and canceled checks show that the decedent bought
from Mamiye and Lloyds (primarily at its Fifth Avenue store in
New York) various assets which included diamonds, rubies,
sapphires, and emeralds, either loose or as pieces of jewelry,
and ivory, jade, rugs, furniture, and Chinese artifacts. We set
forth these receipts and checks in four categories.
a. Receipts From Lloyds to the Decedent
Lloyds gave to the decedent nine receipts reflecting
$1,421,000 of merchandise that it sold to him during 1988 and
1989. Three of the nine receipts relate to purchases of $650,000
made on January 16, 1988. One of the nine receipts relates to
purchases of $235,000 made on May 4, 1988. One of the nine
receipts relates to purchases of $235,000 made on May 5, 1988.
Three of the nine receipts relate to purchases of $276,000 made
13(...continued)
33 years old, respectively.
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