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to the plans and, with the exception of advance contributions
made with respect to vacation time and severance pay, petitioner
did not make any such contributions during the taxable years at
issue. No contributions were made by petitioner to any of the
CBA Plans during the relevant period that were not required by
collective bargaining agreements.
Petitioner's subsidiaries, for public financial reporting
purposes, accounted for their contributions to the CBA Plans in
one of 2 ways. Skaggs Alpha Beta (for the plans to which it
contributed) and Jewel Food Stores (for one of the plans to which
it contributed) calculated contributions paid to the plans during
the corporations' taxable years (regardless of when the covered
services related to the contributions were performed) and
included that total as their contributions expense. For the
other plans to which Jewel Food Stores contributed, and for the
plans to which Alpha Beta Company, Osco Drug Company, and Acme
Markets contributed, the contributions related to covered
services performed during the corporations' taxable years were
treated as contributions expenses (regardless of when those
contributions were paid). For each of the subsidiaries, and for
each taxable year, the amount included as a contributions expense
did not include contributions attributable to covered services
performed after the end of the taxable year.
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