Lucky Stores, Inc. and Subsidiaries - Page 2

               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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