Brookshire Brothers Holding, Inc. and Subsidiaries - Page 3

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               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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