American Stores Company and Subsidiaries - Page 3

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               After concessions, the following 2 issues remain for us to             
          resolve in the present proceeding:  (1) Whether petitioner, in              
          its taxable year ending January 30, 1988 (TYE 8801), properly               
          deducted certain contributions to multiemployer pension plans               
          attributable to services performed after the conclusion of that             
          tax year, and (2) whether petitioner properly deducted certain              
          vacation pay liabilities pursuant to section 463 in its taxable             
          year ended January 31, 1987 (TYE 8701) and in TYE 8801.  The                
          amount of the disputed pension contribution deduction is                    
          $37,839,040.20.  The amounts of the disputed vacation pay                   
          deductions are $24,171,499 in TYE 8701 and $17,927,808 in TYE               
               The facts have been fully stipulated and are found                     
          accordingly.  This reference incorporates the stipulated facts              
          and attached exhibits.                                                      
               Petitioner is a Delaware corporation.  At the time the                 
          petition was filed, petitioner's principal place of business was            
          located in Salt Lake City, Utah.                                            
               Petitioner is the common parent of an affiliated group of              
          corporations, and files a consolidated Federal income tax return            
          annually.  Petitioner filed the petition on behalf of all                   
          eligible members of the group.  For Federal income tax purposes,            
          petitioner elected to file corporate income tax returns on the              
          basis of a 52-53 week fiscal year ending on the Saturday nearest            

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