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 contributionPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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