Estate of Emanuel Trompeter, Deceased, Robin Carol Trompeter Gonzalez and Janet Ilene Trompeter Polachek, Co-Executors - Page 7

          million of sales which it had recently made to the decedent, and            
          it informed respondent that those receipts did not necessarily              
          reflect all of the sales which it had made to the decedent.                 
          Respondent’s determination of the estate’s unreported assets also           
          was supported by respondent’s examination of canceled checks of             
          the decedent payable primarily to Mamiye and Lloyds, respondent’s           
          comparison of the items on the receipts furnished by Mamiye and             
          Lloyds with the assets described by the individuals with whom               
          respondent conversed, and respondent’s seizure from the Trust’s             
          safe deposit box at Union Bank (safe deposit box) of unreported             
          assets consisting of various bullion coins, 41 gold coins, 14               
          loose gemstones, and 11 items of jewelry.                                   
               Following our trial of this case and our detailed review of            
          the record, we agreed with respondent that the estate had failed            
          to report a significant amount of assets.  The estate conceded              
          that this amount was a little over $1 million.  We were persuaded           
          that the amount was much greater.  We also were persuaded,                  
          however, that this amount was less than the $14 million                     
          determined by respondent.  We proceeded to make an approximation            
          of the fair market value of assets omitted from the taxable                 
          estate, recognizing that valuation is not an exact science and              
          that the task before us was difficult in that the coexecutors had           
          concealed information and assets from their accountants,                    
          respondent, and this Court.                                                 

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