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.
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