T.C. Memo. 1998-35
UNITED STATES TAX COURT
ESTATE OF EMANUEL TROMPETER, DECEASED, ROBIN CAROL TROMPETER
GONZALEZ AND JANET ILENE TROMPETER POLACHEK, CO-EXECUTORS,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.
Docket No. 11170-95. Filed January 27, 1998.
D died on Mar. 18, 1992, and his Federal estate
tax return reported the value of his estate (E) on the
alternate valuation date. R determined higher values
for many of the reported assets, assigned values for
unreported assets, and disallowed certain deductions.
R also determined that E was liable for the fraud
penalty under sec. 6663(a), I.R.C. Held: Taxable
estate redetermined, including redeterminations of fair
market value. Held, further, E is liable for the fraud
penalty.
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