Lucky Stores, Inc. and Subsidiaries - Page 14

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               During the relevant period, petitioner made monthly                    
          contributions to 29 CBA Plans on behalf of its unionized                    
          employees.  For each CBA Plan, the amount of the monthly                    
          contribution was the arithmetical result obtained by multiplying            
          the "covered hours worked" (the number of hours worked during the           
          month by employees covered under the respective collective                  
          bargaining agreement (CBA)) by the "contribution rate", a dollar            
          amount set forth in the CBA.                                                
               For any given taxable year prior to the Current Taxable                
          Year, petitioner deducted the 12 monthly contributions that were            
          calculated from covered hours worked during such year.  Then, as            
          to the Current Taxable Year, petitioner changed its method of               
          calculating its deduction.  For the Current Taxable Year,                   
          petitioner obtained an extension to October 15, 1986, of the time           
          within which to file its return.  Between the date on which the             
          Current Taxable Year ended and the due date of the return, as               
          extended, petitioner made eight or in some cases nine monthly               
          contributions to the CBA Plans, and claimed these post-yearend              
          contributions (herein for convenience called "grace period                  
          contributions") as a deduction for the Current Taxable Year, in             
          addition to the usual 12 monthly contributions.  As to the                  

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