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FINDINGS OF FACT
Introduction
Some of the facts have been stipulated and are so found.
The stipulations of facts filed by the parties, with accompanying
exhibits, are incorporated herein by this reference. Petitioner
has its principal place of business in Columbus, Ohio.1
Business of Petitioner
Petitioner is one of the largest specialty retailers in the
United States. During the years at issue, it sold its
merchandise both in its own stores and by catalog. Among the
well-known stores owned by petitioner were The Limited, Lane
Bryant, Lerner New York, Victoria’s Secret, and Abercrombie &
Fitch. Petitioner earned its income primarily from the sale of
garments. A foreign subsidiary of petitioner manufactured many
of those garments or contracted with others for their
manufacture.
Payments by Customers
Merchandise sold by petitioner is paid for with cash, by
check, or by credit card. Petitioner accepts two types of credit
cards: (1) petitioner’s private-label credit card, which is
honored only in one or more of petitioner's stores, and (2) a
1 In the stipulations, the parties have adopted the convention
of referring to the affiliated group as “petitioner”; hereafter,
we will use the term “petitioner” to refer both to the affiliated
group and to any member, so long as specific identification of
that member is unnecessary.
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Last modified: May 25, 2011