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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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