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ESTATE OF TROMPETER v. COMMISSIONER

Docket No. 11170-95.

75 T.C.M. 1653 (1998)

T.C. Memo. 1998-35

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

United States Tax Court.

Filed January 27, 1998.

Attorney(s) appearing for the Case

Robert A. Levinson, Encino, Calif., Avram Salkin, Bruce I. Hochman, Charles P. Rettig, and Frederic J. Adam, for the petitioner. Irene Carroll, Anne E. Daugharty, Linette Angelastro, and Donald E. Osteen, the for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

This case is before the Court pursuant to a petition filed on behalf of the Estate of Emanuel Trompeter (the estate) to redetermine respondent's determination of a $22,833,693 deficiency in Federal estate tax and a $14,875,909 fraud penalty under section 6663(a). Respondent determined, as an alternative to the fraud penalty, that the estate is liable for an accuracy-related penalty for negligence and gross...

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