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Docket No. 5508-99
Eddie Cordes, Inc. Successor by Merger with Cordes Finance Corp.:
Accuracy-related Fraud
penalties penalties
Year Deficiency sec. 6662(a) sec. 6663
1994 $328,625 -0- $246,654
1995 298,393 $59,861 (685)
Docket No. 7369-99
Edmund J. and June J. Cordes:
Accuracy-related Fraud
penalties penalties
Year Deficiency sec. 6662(a) sec. 6663
1994 $1,806,379 $211,212 $562,739
1995 1,162,589 108,851 463,750
Separate petitions were filed contesting respondent’s
determinations. These cases present common issues of fact and
law and were consolidated for trial, briefing, and opinion
pursuant to Rule 141(a).
After concessions,3 the only issues for decision are:
1) Whether any of the individual petitioners received
constructive dividends from Cordes Finance Corp. (CFC) and/or
Eddie Cordes, Inc. (ECI), in 1994 and/or 1995, and, if so, in
what amounts;
2) whether interest earned on certain notes in 1994 and
1995 is properly included in CFC’s or Edmund J. Cordes’s (Mr.
3Many issues in these consolidated cases have been settled
or conceded by the parties or are deemed by this Court to be
conceded. Other issues raised by the parties are computational
in nature. In the interest of space, these conceded, deemed
conceded, computational, and settled issues, and their respective
dispositions, are set forth in Appendix, Summary of Conceded,
Deemed Conceded, Computational, and Settled Issues. We
incorporate those dispositions into our opinion by this
reference.
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