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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts is incorporated herein by this
reference. Petitioner's Forms 1120, U.S. Corporation Income Tax
Return, for the years in issue were filed with respondent's
Service Center in Andover, Massachusetts. At the time it filed
the petition in this case, petitioner's principal place of
business was located in Boston, Massachusetts.
General Background
FMR Corp. is the parent holding company of an affiliated
group of corporations. Hereinafter we shall refer to FMR Corp. as
petitioner. Petitioner provides investment management services,
through its operating subsidiary, Fidelity Management & Research
Co. (FMR Co.), to regulated investment companies (or RIC's, which
are commonly known to the investing public as "mutual funds")
under a contract with each RIC. As of January 1, 1996,
petitioner provided such services to 232 RIC's.
Petitioner began in 1946 as the investment adviser to a
single RIC, the Fidelity Fund, which invested in stocks. For
most of the following three decades, petitioner created and
rendered services to additional RIC's, which also invested only
in stocks. In the 1970's, petitioner began to create RIC's that
invested in bonds (fixed income funds) and in short-term
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