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results from a disallowance of claimed investment tax credits
attributable to leasehold improvements, furnishings, and
equipment acquired for, and placed in service at, petitioners’
corporate headquarters during petitioners’ 1986 taxable year.
Petitioners now claim they are entitled to an investment credit
in an amount greater than claimed on their return. The sole
issue for decision is whether petitioners (hereinafter referred
to as Payless) are entitled to an investment tax credit pursuant
to one of the transition rules contained in the Tax Reform Act of
1986 (TRA), Pub. L. 99-514, 100 Stat. 2085.1 An unrelated issue
involving a claimed net operating loss carryback will require a
Rule 1552 computation.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Payless’ principal place
of business was located in Kansas City, Missouri, when the
petition was filed. Payless has had its corporate headquarters
1The transition rules relied on are secs. 204(a)(7) (world
headquarters rule) and 203(b)(1)(C) (equipped building rule) of
the Tax Reform Act of 1986 (TRA), Pub. L. 99-514, 100 Stat. 2085,
2156, 2144, respectively.
2Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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