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FINDINGS OF FACT
I. Overview
Some of the facts have been stipulated and are so found.
The stipulations and the exhibits submitted therewith are
incorporated herein by this reference. The decedent was born in
New York on February 22, 1919, and he resided in Thousand Oaks,
California, when he died on March 18, 1992. At the time of the
filing of the petition, Ms. Gonzalez resided in Florida, and
Ms. Polachek resided in California.
The coexecutors are the decedent's sole beneficiaries and
his only surviving children. Their mother is Ms. Trompeter.
Each coexecutor is college educated, has extensive work
experience, and knows about her obligation to file valid Federal
tax returns. The coexecutors enjoy a close and friendly
relationship with Ms. Trompeter.
The coexecutors are cotrustees of the Emanuel Trompeter
Trust (the Trust), a trust that holds most of the decedent's
assets. The Trust was revocable during the decedent's life,
and the decedent was its sole trustee until Ms. Gonzalez
became cotrustee with him in September 1991. Ms. Polachek became
a cotrustee with Ms. Gonzalez following the decedent's death.
II. The Decedent's Sale of Trompeter Electronics, Inc. (TEI)
In 1960, the decedent and Ms. Trompeter formed TEI. TEI
manufactured mainly electronic components which assisted in the
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