-33-
four referenced diamonds purchased from Mamiye were included in
the assets seized by respondent from the safe deposit box.
d. Checks From the Decedent to Mamiye
During 1988 and 1989, the decedent wrote Mamiye the
following checks for the purchase of merchandise:
Check Number Check Date Check Amount
764 Jan. 16, 1988 $6,000
954 Feb. 16, 1989 50,000
981 Apr. 6, 1989 75,000
982 Apr. 9, 1989 45,000
993 May 5, 1989 175,000
1080 Sept. 7, 1989 7,000
1183 Dec. 22, 1989 15,000
373,000
Check numbers 764, 982, 1080, and 1183 do not relate to any
receipt in the record.
e. Relationship of Receipts and Checks to
Disputed Assets
As to the assets whose existence the parties do not dispute,
some, but not all of these assets, are listed in these receipts.
As to the assets whose existence the parties do dispute, the
receipts reveal that 22 items which are not included in the 25
seized assets were purchased by the decedent from Lloyds but were
not reported on the estate’s Federal estate tax return.15 We
15 Although the two receipts from Mamiye do not list any
item the existence of which is disputed by the parties, these
receipts reflect only the sales from Mamiye to the decedent of
the six loose diamonds.
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