Dover Corporation and Subsidiaries - Page 2

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          Rules 180, 181, and 183.1  The Court agrees with and adopts the             
          Opinion of the Special Trial Judge, which is set forth below.               
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               ARMEN, Special Trial Judge:  This case is before the Court             
          on the motion of Dover Corporation and Subsidiaries (hereinafter            
          petitioner) to restrain assessment or collection, filed pursuant            
          to section 6213(a) and Rule 55.  As explained in greater detail             
          below, we will deny petitioner's motion.                                    
               As an introductory matter, we observe that the taxable years           
          before the Court in the present case are 1992 and 1993; however,            
          for purposes of petitioner's motion, our focus will be on 1993.             
          Nevertheless, because of various carrybacks and carryforwards,              
          taxable years other than those in issue will be discussed, and              
          certain of those other taxable years are before the Court in                
          other dockets.                                                              
               Petitioner reported overpayments of Federal income tax in              
          the amounts of $4,132,466, $10,711,683, and $7,729,449 on its               
          income tax returns for 1990, 1991, and 1992, respectively.  In              
          each instance, petitioner made an election to treat such                    
          overpayment as a credit to be carried forward and applied as an             

          1  Unless otherwise indicated, all section references are to                
          the Internal Revenue Code in effect for the taxable years in                
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     

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