- 8 -
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
1995.
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
7(...continued)
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011