Estate of Emanuel Trompeter, Deceased, Robin Carol Trompeter Gonzalez and Janet Ilene Trompeter Polachek, Co-Executors - Page 2

          report as T.C. Memo. 1998-35 (Trompeter I).  In Trompeter I, we             
          set forth findings of fact as to the substantive issues arising             
          from the notice of deficiency, and we set forth our Memorandum              
          Opinion with respect to those issues.  Subsequently, on                     
          July 22, 1998, we issued a Supplemental Opinion in this case and            
          filed that Supplemental Opinion as 111 T.C. 57 (Trompeter II).              
          Our Supplemental Opinion in Trompeter II decided the parties’               
          disagreement over the mechanics of their computations under Rule            
          155.1  On March 18, 1999, we entered our decision in this case.             
               Through an opinion dated January 30, 2002, and reported at             
          279 F.3d 767, the Court of Appeals for the Ninth Circuit vacated            
          our decision and remanded the case to us to “articulate                     
          sufficiently the basis for * * * [our] ruling on omitted assets             
          and * * * [our] rationale with respect to the valuation of                  
          certain stock”.  Id. at 769.  Specifically, the court directed us           
          to clarify:  (1) The manner in which we arrived at a $4.5 million           
          figure for omitted assets, including a description of the assets            
          and the related fair market values which were included within               
          that figure, (2) our reasoning and analysis behind the use of a             
          4-percent discount rate in valuing the series A exchangeable                
          preferred stock (series A preferred stock) of Sterling Holding              
          Co. (Sterling), and (3) the “well accepted present value                    

               1 Rule references are to the Tax Court Rules of Practice and           
          Procedure.  Unless otherwise indicated, section references are to           
          the applicable versions of the Internal Revenue Code.                       

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