- 10 - tortillas, fried pies, doughnuts, bagels, brown and serve rolls and English muffins. Petitioner began its policy of donating unsold 4-day-old bread and claiming a deduction based on its full retail price in 1983. Prior to 1983, petitioner removed, or "pulled," bread from its shelves two days a week--Mondays and Thursdays. Prior to 1983, petitioner offered its pulled bread for sale, which included three, 4- and 5-day-old bread (depending on the pull day), on discount racks. Bread that did not sell after being on the discount rack for 24 hours was either destroyed or donated. Under petitioner's pre- 1983 policy the pulled bread was discounted approximately 50 percent, for one day only, before it was discarded or donated. Regional and national bakers, such as Continental (Orowheat), Kilpatrick's, and Campbell-Taggertt (Wonder Bread), which have a substantial share of the California pan bread market, sell their pan bread, after that bread is pulled from the retail selling shelves of supermarkets and other retailers, at thrift or bakery outlets at discounts ranging from 20 to 70 percent. Petitioner's donations of bakery products to charitable organizations were "qualified contributions" of inventory under section 170(e)(3)(A) and section 1.170A-4A(b), Income Tax Regs. The retail price of the contributed bakery inventory for purposes of section 170(e)(3)(B) was $3,081,204 for TYE February 3, 1985, and $6,072,353 for TYE February 2, 1986.Page: 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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