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Florida corporation with its principal office in Jacksonville,
Florida.
Petitioner was founded in the 1920's, and its stock is
publicly traded on the New York Stock Exchange. Petitioner is a
major food retailer made up of self-service food stores which
sell groceries, meats, seafood, fresh produce, deli/bakery,
pharmaceuticals, and general merchandise items. As of June 30,
1993, petitioner had 1,165 stores in 14 States and the Bahama
Islands.
Petitioner is an accrual basis taxpayer, which has adopted a
52-53 week fiscal year ending on the last Wednesday in June.
Petitioner filed a consolidated corporate Federal income tax
return for its fiscal year ending June 30, 1993.
As of June 30, 1993, petitioner employed approximately
36,000 full-time and 69,000 part-time employees. Since 1988, all
full-time employees who completed 3 months of continuous service
have been eligible for a flexible benefits program called "Winn-
Flex". Under Winn-Flex, employees were furnished certain
benefits that they received automatically and certain optional
benefits among which they could choose. Employees automatically
received life insurance and accident and sickness coverage. The
optional benefits included a medical plan, dental coverage,
vision coverage, supplemental associate life insurance, long-term
disability and two flexible spending accounts for health care and
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