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before the due date for filing petitioner's return (i.e., October
17, 1988). Jewel Food Stores calculated its deduction for
contributions to 2 other plans by adding together contributions
calculated with reference to covered services performed in TYE
8801 and those contributions calculated with reference to covered
services performed after TYE 8801 that were made before the due
date for filing petitioner's return. Alpha Beta Company, Osco
Drug Company, and Acme Stores each calculated its deduction for
contributions to the plans by adding together the contributions
made with reference to covered services performed in TYE 8801 and
those contributions which were related to covered services
performed after TYE 8801 and were made after the end of TYE 8801
but before the due date for filing petitioner's return.
Petitioner claimed a deduction for contributions to the plans of
$101,787,413. Of that amount, $57,607,463 was reflected on
petitioner's books as a TYE 8801 expense, and $44,179,950 was
reflected on Schedule M-1 as an adjustment to petitioner's book
income.
Of the $44,179,950 deducted by petitioner on the Schedule M-
1, $116,285 pertained to amounts contributed by Skaggs Alpha Beta
and Star Markets in February 1988 (and thus was attributable to
covered services performed during TYE 8801). The remaining
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Last modified: May 25, 2011