Estate of Emanuel Trompeter, Deceased, Robin Carol Trompeter Gonzalez and Janet Ilene Trompeter Polachek - Page 68

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               e.  Other Considerations                                               
               Each coexecutor is college educated, and both have extensive           
          work experience.  Each knows about her obligation to file valid             
          Federal tax returns.                                                        
               f.  Conclusion                                                         
               After our detailed review of the facts and circumstances of            
          this case, in conjunction with our analysis of the factors                  
          mentioned above, we conclude that respondent has clearly and                
          convincingly proven that the coexecutors filed the decedent's               
          estate tax return intending to conceal, mislead, or otherwise               
          prevent the collection of tax.  We also conclude that section               
          6664(c) does not insulate the estate from this penalty; we find             
          no reasonable cause for the underpayment, nor that the estate               
          acted in good faith with respect to the underpayment.  We sustain           
          respondent's determination of fraud.                                        
               We have considered all arguments made by the parties, and,             
          to the extent not addressed above, find them to be irrelevant or            
          without merit.                                                              
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          










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