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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.
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