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FINDINGS OF FACT
At all relevant times, petitioner was subject to SEC public
financial reporting and other requirements and, along with its
subsidiaries, operated retail grocery stores located throughout
California and Nevada. Petitioner requested and received from
the Internal Revenue Service an extension to October 15, 1986
within which to file its United States consolidated corporate
income tax return for the fiscal year ended February 2, 1986 (the
Current Taxable Year). The return was timely filed.
Under applicable Internal Revenue Code provisions, employers
are permitted to enter into "qualified" deferred compensation
arrangements to provide retirement and other benefits to
employees and their beneficiaries through single employer plans,
multiple employer plans, and multiemployer plans. Plans that are
not established or maintained pursuant to collective bargaining
agreements are herein for convenience referred to as Multiple
Employer Plans. Plans that are established and maintained
pursuant to collective bargaining agreements are herein for
convenience referred to as CBA Plans, or, on occasion, as
"multiemployer pension plans". In both Multiple Employer Plans
and CBA Plans, the contributions of the participating employers
are pooled and used to provide the benefits of all the covered
employees, former employees, and their beneficiaries. Section
413(b) contains certain rules exclusively applicable to CBA
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