Dover Corporation and Subsidiaries, et al. - Page 2

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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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