Germany's Finance Ministry said it would not return the 18th-century paintings by Bernardo Bellotto to the heirs of Max Emden because he had already fled to Switzerland when he sold them.
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The ministry said in a statement Wednesday this meant the paintings couldn't be considered "forced sales."
Emden's heirs say their grandfather sold the paintings because he needed money after his businesses in Germany were seized by the Nazis.
The federal government's refusal came as the western city of Cologne announced it would return 11 other drawings to the heirs of Jewish collectors who sold them before, or shortly after, fleeing Nazi Germany.
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