- 3 - Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some facts have been stipulated and are so found. The stipulations of facts filed by the parties, with accompanying exhibits, are incorporated herein by this reference. The parties have made approximately 180 separate stipulations of fact, occupying 50 pages, and there are 120 accompanying exhibits. We will set forth only those stipulated facts that are necessary to understand our report, along with other facts that we find. I. Background A. Petitioner Petitioner is a Minnesota corporation with its principal office in Minneapolis, Minnesota. Petitioner makes its Federal income tax return on the basis of a fiscal year ending during January of each year (we shall refer to petitioner's taxable year ending within a year simply by referring to that year, e.g., “1984” for petitioner's taxable year ending January 28, 1984). During 1984, petitioner was a retailer operating 1,075 stores in 47 States, the District of Columbia, and Puerto Rico. Petitioner's operations included a rapidly growing low margin department store chain in 22 States called Target and a regional department store company called Dayton's.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011