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collections, ancient Chinese artifacts, and handmade unique wool
rug. He alleged that these goods were worth at least $14
million, and that he was due a $1.4 million commission.
Mr. Pasko's claim was denied. On June 15, 1993, Mr. Pasko filed
suit against the estate in the superior court. The suit was
successfully opposed by the estate on demurrer.
V. Preparation and Filing of Estate Tax Return
Right before the decedent died, he discussed his holdings
with Ms. Gonzalez in depth, and he introduced her to his
attorneys, accountants, financial advisers, bankers, and
acquaintances in the coin world. Following the decedent's death,
the coexecutors fired the decedent's long-time counsel and
retained Mr. Levinson to deal with estate tax matters. The
coexecutors also fired the decedent's long-time accountant,
Mr. Schiffer, and retained the accounting firm of Frankel,
Lodgen, Lacher, Golditch & Sardie (Frankel Lodgen) to serve as
the estate's accountants. Ms. Gonzalez instructed Mr. Schiffer
to forward the decedent's records to Frankel Lodgen.
Patricia L. Bates (Ms. Bates) of Frankel Lodgen prepared the
estate and 1991 gift tax returns based primarily on files
received from Mr. Schiffer. Ms. Bates arbitrarily chose in
May 1993 to report the total value of the decedent's Sterling
preferred stock at $15,335. She and the coexecutors were both
aware that prior valuations of his stock had been much greater
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