- 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