ESTATE OF

279 F.3d 767 ESTATE OF Emanuel TROMPETER, Deceased; Robin Carol Gonzalez Trompeter and Janet Ilene Trompeter Polachek, Co-Executors, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. No. 99-70805. United States Court of Appeals, Ninth Circuit. Argued and Submitted September 20, 2001. * Filed January 30, 2002. Avram Salkin (argued), Hochman, Salkin, Rettig, Toscher & Perez, P.C., Beverly Hills, CA; Robert A. Levinson, Levinson & Kaplan, Encino, CA, for petitioners-appellants. Randolph L. Hutter, Department of Justice, Tax Division, Washington, DC, for respondent-appellee. Appeal from a Decision of the United States Tax Court; David Laro, Tax Court Judge, Presiding. Tax Ct. No. 11170-95. Before FERNANDEZ, KLEINFELD, and McKEOWN, Circuit Judges. McKEOWN, Circuit Judge. 1 This case requires us to consider whether the Tax Court detailed its reasoning with the requisite specificity dictated by Leonard Pipeline Contractors v. Comm'r, 142 F.3d 1133, 1135-36 (9th Cir.1998). The Estate of Emanuel Trompeter and Trompeter's daughters, who are co-executors of the estate (collectively, the "Estate"), appeal from a Tax Court decision partially upholding a…