Lucky Stores, Inc. and Subsidiaries - Page 13

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          were to be applied to months ending on or before February 2,                
          1986.                                                                       
               For purposes of paying benefits and plan expenses, all                 
          contributions to each CBA Plan are pooled and no distinction is             
          made between contributions for any specific time period or                  
          contributions made by any particular employer.                              
               Petitioner consulted with the firm of Price Waterhouse                 
          regarding the acceleration of deductions for post-tax yearend               
          contributions to collectively bargained defined benefit pension             
          plans.  The parties stipulated that during the relevant period,             
          Price Waterhouse was engaged in marketing that type of                      
          acceleration to certain clients and other employers that were               
          making required contributions to multiemployer defined benefit              
          pension plans.                                                              
               By section 601(a) and (b)(1) of the Tax Reform Act of 1986,            
          Pub. L. 99-514, 100 Stat. 2085, 2249, the top corporate tax rate            
          was reduced from 46 percent to 34 percent for tax years beginning           
          on or after July 1, 1987.  See S. Rept. 99-313, (1986) 1986-3               
          C.B. (Vol. 3), 219, 220-221; H. Conf. Rept. 99-841 (Vol. 2), at             
          II-59 (1986).  Income in taxable years that included July 1, 1987           
          (other than as the first day of such year) was subject to blended           
          rates.  Id.                                                                 








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