I know people that have specifically requested "Half-Basements" for just this reason.
Then they will build a Closet on a Slab Portion Upstairs and Place the safe Inside it or Build the closet in around it
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Nothing Says "Sucks to be a Thief" like a safe Bolted to the floor and the Back wall of a closet that its built around it. Might as well just steal the whole house at that point.
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