Estate of Trompeter v. Commissioner
United States Tax Court
ESTATE OF EMANUEL TROMPETER, DECEASED, ROBIN CAROL TROMPETER GONZALEZ AND JANET ILENE TROMPETER POLACHEK, CO-EXECUTORS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent *This opinion supplements our Memorandum Opinion in Estate of Trompeter v. Commissioner, T.C. Memo 1998-35. E, an estate, is subject to the fraud penalty of sec. 6663(a), I.R.C.
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ESTATE OF EMANUEL TROMPETER, DECEASED, ROBIN CAROL TROMPETER GONZALEZ AND JANET ILENE TROMPETER POLACHEK, CO-EXECUTORS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent *This opinion supplements our Memorandum Opinion in Estate of Trompeter v. Commissioner, T.C. Memo 1998-35. E, an estate, is subject to the fraud penalty of sec. 6663(a), I.R.C. R computes this penalty based on E's underpayment as determined by taking into account only the deductions which were included on E's Federal estate tax return. E computes its underpayment by also taking into account deductions for expenses,…
1Opinion of the Court
ESTATE OF EMANUEL TROMPETER, DECEASED, ROBIN CAROL TROMPETER GONZALEZ AND JANET ILENE TROMPETER POLACHEK, CO-EXECUTORS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Trompeter v. Commissioner
Tax Ct. Dkt. No. 11170-95
United States Tax Court
111 T.C. 57; 1998 U.S. Tax Ct. LEXIS 38; 111 T.C. No. 2;
July 22, 1998, Filed
ESTATE OF EMANUEL TROMPETER, DECEASED, ROBIN CAROL TROMPETER GONZALEZ AND JANET ILENE TROMPETER POLACHEK, CO-EXECUTORS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent *
E, an estate, is subject to the fraud penalty of sec. 6663(a), I.R.C. R computes…
Also in this document: Concurrence · Chabot; Concurrence · Swift; Concurrence · Halpern; Dissent.
2Cases cited38 opinions
- Helvering v. MitchellSupreme Court of the United States · 1938
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- D. Ginsberg & Sons, Inc. v. PopkinSupreme Court of the United States · 1932
- United States v. Olympic Radio & Television, Inc.Supreme Court of the United States · 1955
- Manning v. Seeley Tube & Box Co.Supreme Court of the United States · 1950
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