Lucky Stores, Inc. and Subsidiaries - Page 7

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          monthly contribution amounts attributable to covered hours or               
          weeks worked between February 3, 1985 and February 2, 1986, and             
          also added the 8 monthly contributions attributable to covered              
          hours or weeks worked from February 3, 1986 through August 31,              
          1986 and made before October 15, 1986 (the date on which                    
          petitioner filed its return for the Current Taxable Year).  In              
          addition, as to certain of the CBA Plans and bargaining units,              
          the dates were February 3, 1986 through September 30, 1986, in              
          which case there were nine monthly contributions instead of                 
          eight.  Thus petitioner claimed a deduction for 19--in some cases           
          20--monthly contributions on the Current Taxable Year return.               
               For fiscal years ending after February 2, 1986, petitioner             
          did not deduct any amounts which had been previously deducted on            
          its Federal income tax return for any prior year.  For fiscal               
          years ending after February 2, 1986, petitioner claimed a                   
          deduction for no more than 12 monthly contributions in any such             
          fiscal year.  The record does not disclose the number of monthly            
          contributions claimed by petitioner for deduction purposes on its           
          Federal income tax return for the taxable year next succeeding              
          the Current Taxable Year.                                                   
               The $36,661,529 in dispute consists of $31,427,131 of                  
          contributions to the Six Large CBA Plans, and $5,234,398 to the             
          19 smaller plans.  In the notice of deficiency, respondent did              
          not disallow the 12 monthly contributions totaling $57,139,406              





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