-4-
gold and gemstones as karat (kt.) and carat (ct.), respectively,
and points. We note that one point equals 1/10 of a karat (or
carat) and simply refer to the weight of gold and gemstones as
karat (or kt.) and carat (or ct.), respectively.
I. Omitted Assets
We determined in Trompeter I that the coexecutors failed to
include $4.5 million of assets in the estate’s taxable estate
(taxable estate). The Court of Appeals for the Ninth Circuit has
directed us “to provide sufficiently detailed findings regarding
the assets (including their valuation)” underlying the $4.5
million.
The decedent died on March 18, 1992. On the Federal estate
tax return of his estate, the coexecutors valued the gross estate
at $26,422,781 and reported that the taxable estate equaled
$12,002,201. Respondent determined in the notice of deficiency
that the coexecutors underreported the taxable estate by
$22,833,693. As part of that determination, respondent
determined that the taxable estate had omitted $14 million of
assets.
Respondent’s determination of the unreported assets was
based mainly on a creditor claim filed against the estate by Joe
Pasko (Pasko), the son of a former female acquaintance of the
decedent, and a document (finder’s fee document) dated
October 17, 1990. Pasko’s claim alleged that he was entitled to
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