Eddie Cordes, Inc., et al. - Page 3




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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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