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For taxable years prior to TYE 8801, petitioner's
subsidiaries computed their deductions for plan contributions in
one of 2 ways. Skaggs Alpha Beta and Jewel Food Stores (for one
of the plans to which it contributed) calculated the
contributions paid to the plans during the corporations' taxable
years (regardless of when the covered services related to the
contributions were performed) and claimed that total as their
deduction. Alpha Beta Company, Osco Drug Company, Acme Markets,
and Jewel Food Stores (for the other plans to which it
contributed) calculated the contributions related to covered
services performed during their taxable years (regardless of when
those contributions were paid) and claimed that total as their
deduction. For each subsidiary, and for each taxable year ending
prior to petitioner's TYE 8801, the total amount claimed as a
deduction for that year did not include any contributions
attributable to covered services performed after the end of that
taxable year.
For TYE 8801, Skaggs Alpha Beta (for the plans to which it
contributed) and Jewel Food Stores (for one of the plans to which
it contributed) computed their deductions for contributions to
the plans claimed on petitioner's Federal income tax returns by
adding together the contributions actually made during TYE 8801
and those contributions made after the end of TYE 8801, but
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Last modified: May 25, 2011