Can you help me formulate an answer using IRAC and a counteranalysis using the following information?

Legislative Act: Section 40-3-6-9A of the state criminal code provides that a noncustodial parent can be convicted of custodial interference when the noncustodial parent "maliciously takes, detains, conceals, entices away, or fails to return the child, without good cause, for a protracted period of time."

Assume there is no case law on point in the jurisdiction relevant the following fact situation.

Facts: Mary has primary custody of her son. The father, Tom, has legal custody for two months in the summer. Tom takes the son for two months in the summer but fails to tell Mary where the son is and does not allow her to communicate with him. Before he leaves with the son, Tom tells Mary, "I'm going to punish you for the way you've treated me."

Assignment: The following are arguments presented by Mary in support of her claim that Tom is in violation of the statue. What are the counterarguments to each argument?

Part A: Tom's actions constitute concealment within the meaning of the statue.