T.C. Memo. 1997-70
UNITED STATES TAX COURT
LUCKY STORES, INC., AND SUBSIDIARIES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 4446-93. Filed February 10, 1997.
P filed a Motion for Reconsideration of our Opinion
reported as Lucky Stores, Inc., & Subs. v. Commissioner, 107
T.C. 1 (1996) on the grounds that we failed to take into
consideration R's long-standing administrative practice of
applying Rev. Rul. 76-28, 1976-1 C.B. 106, to multiemployer
defined benefit plans, and that R failed to fully and fairly
apprise the Court of respondent's actual practices and
interpretations in this regard. In addition, P filed two
Motions Requesting Judicial Notice. Held: P's Motion for
Reconsideration and Motions Requesting Judicial Notice will
be denied.
*This opinion supplements our previously filed Opinion in
Lucky Stores, Inc., & Subs. v. Commissioner, 107 T.C. 1 (1996).
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