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January 31 of any given year. Petitioner requested and received
an extension to October 15, 1987, to file its United States
consolidated corporate income tax return for TYE 8701.
Petitioner requested and received an extension to October 17,
1988, to file its United States consolidated corporate income tax
return for TYE 8801.
Petitioner, through its subsidiaries, primarily engages in
the retail sale of food and drug merchandise. Conjointly, the
subsidiaries represent one of the nation's leading retailers,
operating combination drug/food stores, super drug centers, drug
stores and food stores. During the years in question, petitioner
conducted its principal business activities through wholly owned
subsidiaries and operating divisions, including: Acme Markets,
Inc., Jewel Food Stores, Star Market, Jewel OSCO, Alpha Beta
Company, Skaggs Alpha Beta, and Buttrey Food.
Respondent issued a statutory notice of deficiency on July
26, 1994. After stipulations of agreement executed by the
parties, the remaining issues are: (1) Whether petitioner can
deduct in TYE 8801 certain contributions made to various
multiemployer pension plans in the months after January 30, 1988,
but before the extended due date for filing its return, and (2)
whether petitioner is entitled to certain vacation pay accrual
adjustments pursuant to section 463 for TYE 8701 and TYE 8801.
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