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he was the husband of Judith M. Allen during 1995. John R.
Allen, Jr., was the husband of Susan S. Allen. Warren L. Allen,
Jr., was the husband of Amantha S. Allen. Each petitioner and
his wife (with the exception of Sally F. Allen) resided in
Delaware when the petitions were filed. Sally F. Allen was
deceased at that time, and the executor of her estate was (and
is) John R. Allen, Jr.
Allen Family Foods, Inc. (Foods), is an S corporation that
was incorporated under Delaware law. Its business is the
slaughtering, converting, and processing of chickens into
ready-to-cook whole chickens and chicken parts for sale primarily
to retailers. It computes its income and expenses using an
accrual method of accounting and on the basis of a fiscal year
ending on the Saturday nearest April 30. It filed a Form 1120S,
U.S. Income Tax Return for an S Corporation, for its fiscal years
ended in 1994 and 1995 (its 1994 and 1995 taxable years,
respectively).
Petitioners are descendants of Charles C. Allen, the founder
of the family poultry business, and they owned all of Foods’
outstanding stock during its 1994 and 1995 taxable years. The
number of the shares that they each owned and the percentage of
their respective ownership interests were as follows:
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