Estate of Emanuel Trompeter, Robin Carol Trompeter Gonzalez and Janet Ilene Trompeter Polacheck, Co-Executors v. Commissioner
United States Tax Court
1Opinion of the Court
111 T.C. No. 2
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* Docket No. 11170-95. Filed July 22, 1998. 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, such as professional fees…
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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