- 2 - 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and Rules 180, 181, and 183.2 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: These consolidated cases are before the Court on the motions of Dover Corporation and its subsidiaries (hereinafter petitioner) to enforce refund of an overpayment, filed pursuant to section 6512(b)(2) and Rule 260 at each of the five above-numbered dockets. As explained in greater detail below, we will deny petitioner's motions. By way of introduction, we observe that the taxable years that are before the Court in the present five cases are 1982 through 1989. Nevertheless, as will become apparent, the disposition of petitioner's motions requires that we focus on 1993 and certain other taxable years that are not in issue in the present cases. Background Respondent issued separate notices of deficiency to petitioner in which respondent determined deficiencies in petitioner's Federal corporate income taxes for the years as follows: 2 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.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011