Newhouse Broadcasting Corporation and Subsidiaries, et al. - Page 3

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           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.                                                                              





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