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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 computes
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