Dover Corporation and Subsidiaries - Page 6

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          Specifically, petitioner requested:  “H&C be granted an extension           
          of time to make an election: (a) * * * to be disregarded as an              
          entity separate from its owner for U.S. tax purposes and (b)                
          effective immediately prior to the sale of stock in H&C by Dover            
          UK to Thyssen UK.”2  In the request for 9100 relief, petitioner             
          stated that the date of the sale was June 30, 1997, and, on the             
          Form 8832, Entity Classification Election (Form 8832), attached             
          to the request for 9100 relief, it set forth June 30, 1997, as              
          the proposed effective date of the election.                                
               Initially, respondent was reluctant to grant the request for           
          9100 relief, in large part, because, in respondent’s view,                  
          petitioner should not be entitled to benefits it might claim                
          resulted from the disregarded entity election; i.e., the                    
          avoidance of FPHCI on the deemed sale of the H&C assets.                    
          However, after representatives of petitioner and respondent                 
          conferred, and petitioner made a supplemental submission,                   
          respondent, on March 31, 2000, granted the requested relief.                
          Specifically, respondent granted to H&C “an extension of time for           
          making the election to be disregarded as an entity separate from            


               2  Pursuant to sec. 301.7701-3(c)(1)(iii), Proced. & Admin.            
          Regs., H&C could have made the election to be a disregarded                 
          entity at any time within 75 days after the date (June 30, 1997),           
          specified on the election form (Form 8832, Entity Classification            
          Election).  Because petitioner inadvertently missed that                    
          deadline, it was required to request an extension of time,                  
          pursuant to secs. 301.9100-1(c) and 301.9100-3, Proced. & Admin.            
          Regs., to make the election.                                                




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