Estate of Emanuel Trompeter, Deceased, Robin Carol Trompeter Gonzalez and Janet Ilene Trompeter Polachek - Page 3

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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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