- 2 -
Robert A. Levinson, Avram Salkin, Bruce I. Hochman,
Charles P. Rettig, and Frederic J. Adam, for petitioner.
Irene Carroll, Anne E. Daugharty, Linette Angelastro,
and Donald E. Osteen, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: This case is before the Court pursuant to a
petition filed on behalf of the Estate of Emanuel Trompeter (the
estate) to redetermine respondent's determination of a
$22,833,693 deficiency in Federal estate tax and a $14,875,909
fraud penalty under section 6663(a). Respondent determined, as
an alternative to the fraud penalty, that the estate is liable
for an accuracy-related penalty for negligence and gross
valuation misstatement under section 6662.
Following concessions, the primary issue that the Court must
decide is the September 18, 1992, fair market value of the
following assets which the parties agree are included in the
gross estate of Emanuel Trompeter (the decedent):
1. 1,533.482 shares of Sterling Holding Co. (Sterling)
series A exchangeable preferred stock (Sterling preferred stock).
We hold that the applicable value (including accrued dividends)
is $1,974,845.
2. Two hundred twenty seven rare gold coins. We hold that
the applicable value is $8,129,523.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011