Zeeman Manufacturing Company, Inc. - Page 2

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               In the notice of deficiency, respondent determined                     
          deficiencies in and penalties on petitioner's Federal income tax            
          as follows:                                                                 
               Taxable                            Accuracy-related                    
               Year Ending                             Penalties                      
               June 30             Deficiency             Sec. 6662                   
             1991                  $225,794            $45,159                        
              1992                318,517             63,703                         
              1993                379,025             75,805                         
               Petitioner has its principal place of business in Chamblee,            
          Georgia.                                                                    
               Prior to the issuance of the notice of deficiency and in               
          accordance with section 534(b), respondent issued to petitioner a           
          Notice of Intent to Assert Accumulated Earnings Tax stating that            
          respondent intended to issue a notice of deficiency for the tax             
          on accumulated earnings pursuant to section 531.  Petitioner                
          submitted a timely statement pursuant to section 534(c).                    
          Subsequently, respondent issued a notice of deficiency in which             
          respondent determined, inter alia, that petitioner is liable for            
          the accumulated earnings tax pursuant to section 531 for                    
          petitioner's taxable years ended June 30, 1991, 1992, and 1993.             
          Petitioner filed a petition with this Court, and respondent filed           
          an answer.  After the instant case was calendared for trial,                
          respondent filed the instant motion to shift the burden of proof.           

          1(...continued)                                                             
          are to the Internal Revenue Code as in effect for the taxable               
          years before the Court, and all Rule references are to the Tax              
          Court Rules of Practice and Procedure.                                      




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