NIMS, Judge: Respondent determined the following
deficiencies in petitioner's Federal income tax:
Taxable Year Ending (TYE) Deficiency
Jan. 30, 1983 $8,797,328
Feb. 3, 1985 2,175,135
Feb. 2, 1986 48,255,017
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the years at
issue, and all Rule references are to Tax Court Rules of Practice
and Procedure.
This case involves a number of issues that are being handled
in proceedings that are separate from the one under present
consideration. In this proceeding, the parties dispute the fair
market value of bakery products, unsold canned goods, and other
general merchandise contributed to food banks by petitioner
during the years in issue.
On its Federal income tax returns for TYE February 3, 1985
and TYE February 2, 1986, the charitable contribution years in
issue, petitioner claimed deductions for the above charitable
contributions in the amounts of $576,258 and $909,055,
respectively. The parties agree that the cost basis of the
contributed bakery inventory for purposes of section 170(e)(3)(B)
was $1,753,495 for TYE February 3, 1985, and $3,471,236 for TYE
February 2, 1986.
For the taxable years in issue, petitioner concedes the
portions of its claimed deductions relating to its contribution
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