Estate of Emanuel Trompeter, Deceased, Robin Carol Trompeter Gonzalez and Janet Ilene Trompeter Polachek - Page 22

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          estate was returned at $26,422,781.  The taxable estate was                 
          returned at $12,002,201.                                                    
          VI.  Reward Agreement                                                       
               Various sources alerted respondent that the estate may have            
          underpaid its estate tax.  Among other things, several                      
          individuals supplied respondent with information regarding the              
          decedent's holdings and estimated values.  One of the primary               
          catalysts for respondent's audit of the decedent's estate tax               
          return was an informant's claim filed by Mr. Goldberg and his               
          cousin Larry Goldberg (collectively the Goldbergs).  Following              
          numerous discussions, respondent and the Goldbergs entered into a           
          reward agreement, under which the Goldbergs agreed to provide               
          respondent with certain information on the decedent and his                 
          estate in exchange for a reward not to exceed $1 million.  Under            
          the agreement, the Goldbergs were required, if necessary, to                
          testify before any court, grand jury, or any other forum                    
          investigating the decedent or his estate.  Payment of the reward            
          was contingent on respondent's conclusion that respondent                   
          received valuable information from the Goldbergs which was not              
          previously known and which directly resulted in the collection of           
          taxes, additions to tax, fines, and/or penalties from the estate.           
          Under the reward agreement, the Goldbergs were not entitled to a            
          reward if the evidence furnished was of no value.                           
          VII.  Respondent's Jeopardy Assessment                                      





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