Estate of Emanuel Trompeter, Deceased, Robin Carol Trompeter Gonzalez and Janet Ilene Trompeter Polachek, Co-Executors - Page 3

          formulae” referenced and applied in our report.  Id. at 771-773.            
          The court also stated that, upon remand and following the                   
          requisite clarification, we shall consider whether it is                    
          appropriate to revisit our conclusions as to fraud.  Id. at                 
          773-774.  The court noted that “In directing this approach, we do           
          not pass judgment on the Tax Court’s multiple, careful, and                 
          well-documented findings in this arena, nor do we suggest that a            
          remand will necessarily result in a different outcome with                  
          respect to fraud.”  Id. at 774.                                             
               We divide this Supplemental Memorandum Opinion into the                
          following three primary sections:  (1) “Omitted Assets”,                    
          (2) “Present Value Formulae and Discount Rate of Four Percent”,             
          and (3) “Determination of Fraud in Trompeter I”.  We made and set           
          forth in Trompeter I extensive findings of fact.  For purposes of           
          this Supplemental Memorandum Opinion, we repeat those findings              
          and find additional facts only to the extent necessary.  For                
          purposes of convenience and clarity, we include those findings in           
          our analysis.2  As we did in Trompeter I, we refer to Emanuel               
          Trompeter as the decedent, we refer to the decedent’s estate as             
          the estate, and we refer collectively to Robin Carol Trompeter              
          Gonzalez (Gonzalez) and Janet Ilene Trompeter Polachek (Polachek)           
          as the coexecutors.  The parties routinely refer to the weight of           

               2 We also in our analysis set forth various calculations               
          underlying our findings and our Supplemental Memorandum Opinion.            
          We round the results of those calculations as appropriate.                  

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