- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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