ESTATE OF TROMPETER v. COMMISSIONER

Docket No. 11170-95.

111 T.C. 57 (1998)

ESTATE OF EMANUEL TROMPETER, DECEASED, ROBIN CAROL TROMPETER GONZALEZ AND JANET ILENE TROMPETER POLACHEK, CO-EXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 22, 1998.


Attorney(s) appearing for the Case

Robert A. Levinson and Avram Salkin, for petitioner.

Irene Scott Carroll, for respondent.


SUPPLEMENTAL OPINION

LARO, Judge:

The dispute herein involves the Rule 155 computation mandated by the Court's Memorandum Opinion filed as Estate of Trompeter v. Commissioner, T.C. Memo. 1998-35. The issue before the Court is one of first impression; namely, whether an estate's underpayment for purposes of computing the fraud penalty is determined based solely on expenses which are included on the Federal...

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