Legal Opinion

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

United States Tax Court

Decided July 22, 1998No. 11170-95Unknown

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

  1. Helvering v. MitchellSupreme Court of the United States · 1938
  2. Badaracco v. CommissionerSupreme Court of the United States · 1984
  3. D. Ginsberg & Sons, Inc. v. PopkinSupreme Court of the United States · 1932
  4. United States v. Olympic Radio & Television, Inc.Supreme Court of the United States · 1955
  5. Manning v. Seeley Tube & Box Co.Supreme Court of the United States · 1950

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