- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011