Dave Graf Daimler - Page 12




                                       - 12 -                                         
                                                  Fraud Penalty Under                 
               Taxable Year Ended   Deficiency    Section 6663                        
                    1989           $30,397             $22,798                        
                    1990           59,085              44,314                         
                    1991           44,645              33,484                         
                    1992           39,040              29,280                         
               Respondent issued to Dieter Electronics a notice with                  
          respect to the taxable years ended January 31, 1990, January 31,            
          1991, and January 31, 1992, and a separate notice with respect to           
          the taxable year ended January 31, 1993.  In those notices,                 
          respondent determined the following deficiencies in, and fraud              
          penalties under section 6663, on the Company’s tax:                         
                                                  Fraud Penalty Under                 
               Taxable Year Ended    Deficiency   Section 6663                        
               January 31, 1990    $25,945             $19,459                        
               January 31, 1991    43,016              32,262                         
               January 31, 1992    39,038              29,279                         
               January 31, 1993    29,147              21,860                         
               Mr. Daimler and Dieter Electronics did not file responses to           
          respondent’s motions.  The undenied admissions in these cases               
          establish facts requiring a decision against Mr. Daimler in                 
          docket No. 14606-94 and against Dieter Electronics in docket No.            
          14608-94 with respect to both the deficiency determinations in              
          the notices on which they have the burden of proof and the fraud            
          penalty determinations in those notices on which respondent has             
          the burden of proof by clear and convincing evidence.  Accord-              
          ingly, respondent’s motion for summary judgment as to Mr. Daimler           
          in docket No. 14606-94 and as to Dieter Electronics in docket No.           






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