Dover Corporation and Subsidiaries - Page 8

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          addition, by letter dated January 6, 1997, respondent requested a           
          payment from petitioner in the amount of $6,997,537.51 for taxes,           
          penalties, and interest purportedly due for 1995.  Respondent               
          issued a further written request for payment for 1995 on February           
          17, 1997.                                                                   
               On March 4, 1997, petitioner filed a Motion to Restrain                
          Assessment or Collection in the present case.  Petitioner seeks             
          an order from the Court restraining respondent from further                 
          assessment or collection of taxes for the years 1993, 1994, and             
               On March 18, 1997, respondent filed an objection to                    
          petitioner's Motion to Restrain Assessment or Collection.                   
          Respondent contends that the amounts that have been assessed and            
          that are the object of respondent's collection efforts are the              
          amounts that are due because of respondent's decision not to                
          accept petitioner's amended returns for 1990 and 1991.  In this             
          regard, respondent asserts that the assessments in question are             

          1994, and the $2,082,646 amount listed as due in respondent's               
          notice of intent to levy issued to petitioner on Dec. 30, 1996,             
          is attributable to respondent's application of a net refund of              
          approximately $4,000,000 due to petitioner for 1982 through 1989            
          as an offset against the amount purportedly due for 1993.                   
          Petitioner contested the application of its refund in this manner           
          by way of Motions to Enforce Refund of an Overpayment filed in              
          docket Nos. 5842-91, 19640-91, 19668-91, 19886-91, and 6102-93.             
          The latter motions are the subject of this Court's Memorandum               
          Opinion, Dover Corporation and Subsidiaries. v. Commissioner,               
          T.C. Memo. 1997-340, a companion case to the present case.                  

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