Wal-Mart Stores, Inc. and Subsidiaries - Page 3

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                                  FINDINGS OF FACT                                    
          I.  Background                                                              
               A.  General Information                                                
               Some of the facts have been stipulated and are so found.               
          The stipulated facts and exhibits submitted therewith are                   
          incorporated herein by this reference.  Petitioners comprise an             
          affiliated group of corporations that use an accrual method of              
          accounting for financial accounting and tax purposes.  They filed           
          Federal consolidated income tax returns and amended Federal                 
          consolidated income tax returns for the subject years.  Their               
          common parent is Wal-Mart Stores, Inc. (Parent).  Parent's                  
          principal place of business was in Bentonville, Arkansas, when it           
          petitioned the Court.                                                       
               At all relevant times, Kuhn's-Big K Stores Corp. (Kuhn's)              
          and Big K Edwards, Inc. (Edwards), were two of Parent's                     
          subsidiaries, and Sam's Wholesale Clubs (Sam's) was one of                  
          Parent's divisions.  (We hereinafter use the name "Wal-Mart" to             
          refer collectively to Parent (without regard to Sam's), Kuhn's,             
          and Edwards.  We hereinafter use the term "petitioners" to refer            
          collectively to Wal-Mart and Sam's.)                                        
               Sam's operated its stores (clubs) on a discount warehouse              
          basis.  Wal-Mart operated its stores as mass discount retailers.            
          Each Wal-Mart store contained up to 37 departments, and, in the             
          aggregate, these departments carried a wide range of merchandise,           
          including home furnishings, electrical appliances, automotive and           




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