-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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