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C. Scope of Petitioners' Operations
Wal-Mart is one of the largest operators of mass merchandise
retail stores in the United States. During the subject years,
the numbers of Wal-Mart's stores and Sam's clubs were as follows:
Taxable Year Wal-Mart Sam's
1983 642 3
1984 745 11
1985 859 23
1986 980 49
Many of these stores were open to the public 24 hours a day.
During the subject years, Wal-Mart purchased and sold
products labeled with the manufacturer's name (name brands), as
well as products with its own name brand. The dollar amounts of
petitioners' purchases and the retail values of its net sales
were as follows:
Purchases Sales
Year Wal-Mart Sam's Wal-Mart Sam's
1983 $3,543,245,308 $41,192,081 $4,566,514,170 $37,364,011
1984 4,808,957,832 232,156,657 6,068,673,313 221,585,916
1985 5,855,108,264 749,927,690 7,501,658,005 776,483,444
1986 8,037,262,151 1,608,040,382 9,933,879,035 1,670,806,324
A typical Wal-Mart store averaged 53,000, 55,000, 57,000,
and 59,000 square feet in the respective taxable years, and
petitioners' total square footage of retail space increased from
27.7 million in the 1983 taxable year to 63 million in the 1986
taxable year. Wal-Mart's stores carried between 60,000 and
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