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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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