Lucky Stores, Inc. and Subsidiaries - Page 1

                                 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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