Lucky Stores, Inc. and Subsidiaries - Page 2

               Barry W. Homer, Eric W. Jorgensen, and Grady M. Bolding, for           
               Alan Summers, Kevin G. Croke, and Elizabeth L. Groenewegen,            
          for respondent.                                                             

               NIMS, Judge:  Respondent determined the following                      
          deficiencies in petitioner's Federal income tax:                            

               Fiscal year ended (FYE)            Deficiency                          
               January 30, 1983                   $8,797,328                          
               February 3, 1985                   2,175,135                           
               February 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 the Tax Court Rules of                
          Practice and Procedure.                                                     
               This case involves a number of issues.  The only issue to be           
          resolved in the present proceeding is petitioner's claim to a               
          deduction for union negotiated pension plan contributions for the           
          taxable year ended February 2, 1986.  The amount of the disputed            
          deduction is $36,661,529.                                                   
               Most of the facts have been stipulated and are so found.               
               Petitioner is a Delaware corporation.  At the time the                 
          petition was filed, petitioner's principal place of business was            
          located in Dublin, California.                                              

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

Last modified: May 25, 2011