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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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Last modified: May 25, 2011