Dover Corporation and Subsidiaries - Page 6

                                        - 6 -                                         

          claimed on petitioner's amended return for 1991.  Consistent with           
          this adjustment, respondent determined that petitioner failed to            
          pay $4,905,029.16 of the $75,758,778 in total tax reported by               
          petitioner on its income tax return for 1993.6  Shortly                     
          thereafter, on December 19, 1994, respondent issued a bill to               
          petitioner for the taxable year 1993 requesting the payment of              
          $5,455,695.74, consisting of tax in the amount of $4,905,029.16,            
          penalties in the amount of $245,251.46, and interest in the                 
          amount of $305,415.12.                                                      
               In the interim, on November 18, 1994, petitioner filed a               
          petition, which was assigned docket No. 21334-94, contesting                
          respondent's determinations as set forth in the notice of                   
          deficiency for the taxable years 1990 and 1991.  In addition to             
          contesting respondent's determinations, the petition at docket              
          No. 21334-94 includes allegations that petitioner is entitled to            
          overpayments for the taxable years 1990 and 1991 consistent with            
          the reporting position taken by petitioner in its amended returns           
          for 1990 and 1991, including the carryback of the $32,797,961 net           

          6  As a further consequence of the rejection of the                         
          $12,621,181 credit claimed on petitioner's income tax return for            
          1993, respondent did not recognize petitioner's election to treat           
          its claimed overpayment for 1993 as a credit to be carried                  
          forward and applied as an estimated tax payment for 1994 and                
          1995.  This resulted in respondent's conclusion that petitioner             
          failed to pay a portion of the tax that petitioner reported on              
          its income tax returns for 1994 and 1995.                                   

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  Next

Last modified: May 25, 2011