Publix Supermarkets, Inc. v. United States

OPINION

HORN, Judge.

BACKGROUND

The plaintiff, Publix Supermarkets, Inc., is a Florida corporation engaged in the business of owning and operating retail *162food and drug stores.1 Publix Supermarkets are self-service retail markets which sell basic grocery products, including general merchandise, health and beauty aids, and non-perishable and perishable food items. During the 1981 tax year, the plaintiff operated 251 supermarkets in the State of Florida and had sales totaling approximately $2.37 billion. In 1982, the plaintiff’s business expanded to include 262 Florida supermarkets, with total…