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