- 3 - Background This case was submitted fully stipulated in accordance with Rule 122, and the facts are so found. The stipulations of the parties, with accompanying exhibits, are incorporated herein by this reference. Petitioner’s Operations Brookshire Brothers Holding, Inc., is, and was at the time of filing the petition in this case, a Nevada corporation which maintained its principal offices in Lake Charles, Louisiana. Brookshire Brothers Holding, Inc., and its subsidiaries (hereinafter collectively petitioner) are an affiliated group of corporations which for all relevant tax years filed a consolidated Federal income tax return. As a significant component of its activities, petitioner is engaged in the business of operating a chain of grocery stores. In September of 1991, petitioner began constructing gas station properties accessible through the parking lots of certain of its grocery stores. These gas stations were subsequently placed into service at grocery store locations throughout the State of Texas. Petitioner’s Accounting Petitioner employs the accrual method of accounting and uses a taxable year ending on the last Saturday of April. Within this overall method of accounting, petitioner generally computesPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011