The Limited, Inc., and Consolidated Subsidiaries - Page 3

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                                  FINDINGS OF FACT                                    
               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 (the stores) 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                

          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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