- 3 -
I. Background
For purposes of the motions, the parties have stipulated
certain facts. We accept the stipulated facts as being true for
purposes of deciding the motions. The stipulation of facts, with
attached documents, is incorporated herein by this reference.
The parties have also filed various memoranda of law, some with
attached affidavits, and other documents. The following
recitation of facts is drawn primarily from the stipulation of
facts. Certain other facts (which facts we deem
noncontroversial) are included in that recitation.
Petitioner is a New York corporation with its principal
office in Staten Island, New York. Petitioner, an accrual basis
taxpayer, engaged in the book publishing business during the
audit years through its then wholly owned subsidiary, Random
House, Inc. (Random House), and Random House’s subsidiaries.2
During the audit years, Random House, through its divisions and
subsidiaries, published books under several trade names, known as
"imprints" in the publishing business. Random House’s major
imprints included Random House ("Random House Adult Trade
Imprint"), Alfred A. Knopf, and Ballantine Books, which accounted
for more than 50 percent of its book sales revenue during the
2 Random House was sold to an unrelated third party on
July 1, 1998.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011