Barry W. Homer, Eric W. Jorgensen, and Grady M. Bolding, for petitioner. 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
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