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The Court also must decide the following secondary issues:
1. Whether the decedent's gross estate includes $14 million
of diamonds, jewels, gems, art, and artifacts that were not
reported on his Federal estate tax return. We hold that his
gross estate includes $4.5 million of these assets.
2. Whether certain other items determined by respondent to
be included in the decedent's gross estate are so included. We
hold they are to the extent and in the amounts stated herein.
3. Whether Sylvia Trompeter (Ms. Trompeter) had a bona fide
claim against the estate because the decedent, her former
husband, failed to disclose the value and extent of his coin
holdings during their divorce proceeding. We hold she did not.
4. Whether the estate is liable for the fraud penalty
determined by respondent under section 6663(a). We hold it is.1
Unless otherwise stated, all section references are to the
applicable provisions of the Internal Revenue Code, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Dollar amounts are rounded to the nearest dollar. The term
"co-executors" refers collectively to the estate's coexecutors,
Robin Carol Trompeter Gonzalez (Ms. Gonzalez) and Janet Ilene
Trompeter Polachek (Ms. Polachek).
1 On account of this holding, we do not decide the
alternative determinations under sec. 6662.
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