American Stores Company and Subsidiaries - Page 9

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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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