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not includable in its gross income. We hold that it does not.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time of the filing of the petition in this case,
petitioner’s principal place of business was in Mechanicsburg,
Pennsylvania.
During the year at issue, petitioner, a corporation orga-
nized under the laws of Pennsylvania, operated several grocery
stores in towns located around Harrisburg, Pennsylvania. During
that year, Super Rite Foods, Inc. (Super Rite), one of peti-
tioner’s suppliers of grocery items since the 1970s, was peti-
tioner’s principal supplier.
In 1998, Scott Karns (Mr. Karns), who at all relevant times
was petitioner’s chief executive officer, concluded that peti-
tioner needed $1.5 million for capital improvements. In that
year, Mr. Karns approached Dale Conklin (Mr. Conklin), who was
then president of Super Rite, to discuss obtaining financial
assistance from Super Rite for petitioner’s capital needs.
At certain times during the relevant time period, certain of
Super Rite’s customers approached it seeking some form of finan-
cial assistance (e.g., an advance of funds, a lease guaranty, a
supply agreement commitment). Although Super Rite preferred that
its customers obtain financial assistance from outside sources,
from time to time (around 10 to 15 times a year) it decided to
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