The Limited, Inc., and Consolidated Subsidiaries - Page 2

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               Joel V. Williamson, Roger J. Jones, Frederic L. Hahn,                  
          Daniel A. Dumezich, Russel R. Young, Neil B. Posner, James P.               
          Fuller, Kenneth B. Clark, Ronald B. Schrotenboer, William F.                
          Colgin, Jr., and Patricia A. Yurchak, for petitioner.                       
               Christine A. Roth, James E. Kagy, Donald K. Rogers, and                
          John Budde, for respondent.                                                 

               HALPERN, Judge:  Petitioner is the common parent corporation           
          of an affiliated group of corporations making a consolidated                
          return of income (the affiliated group).  By notice of deficiency           
          dated September 29, 1995 (the notice), respondent determined                
          deficiencies in Federal income tax for the affiliated group for             
          its taxable years ended February 1, 1992, and January 30, 1993              
          (1992 and 1993, respectively), in the amounts of $72,040,547 and            
          $95,836,934, respectively.  Many of the adjustments giving rise             
          to the deficiencies determined in the notice have been settled,             
          and this report addresses only whether certain transfers during             
          1993 were investments in U.S. property for purposes of those                
          provisions of the Internal Revenue Code dealing with controlled             
          foreign corporations.                                                       
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue.                 

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