Lucky Stores, Inc. and Subsidiaries - Page 3

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          of unsold canned goods and other general merchandise.  The amount           
          of petitioner's charitable deduction that relates to unsold                 
          canned goods and other general merchandise is $85,040 for TYE               
          February 3, 1985 and $198,286 for TYE February 2, 1986.                     
               For TYE February 3, 1985, petitioner concedes the charitable           
          deduction amount of $91,624 relating to its contributions from              
          its stores in Florida.                                                      
               After these concessions, the only contributions at issue are           
          the 4-day-old bread and other "aged" bakery goods from                      
          petitioner's California and Nevada stores.  At the trial, the               
          parties focused almost entirely on the 4-day-old bread, so we               
          proceed upon the assumptions that the dollar amounts of the                 
          donations of other bakery products were relatively insignificant,           
          and that our conclusion as to the value of the 4-day-old bread              
          will establish the method for valuing these items.                          
               The parties also appear to agree that (1) after petitioner's           
          concession of the portions of its claimed deductions for the                
          Florida donations and the donations of canned goods and other               
          general merchandise, (2) after adjusting the cost basis for the             
          remaining contributed bakery inventory, and (3) after the                   
          reduction required under section 170(e)(3)(B), the amounts of               
          charitable deductions in dispute are $663,855 for TYE February 3,           
          1985 and $1,300,558 for TYE February 2, 1986, based on the retail           







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