Lucky Stores v. Commissioner
United States Tax Court
P made donations of its surplus bread inventory to food banks which qualified as permissible charitable donees under sec. 170(e)(3)(A), I.R.C., and claimed charitable contribution deductions based upon full retail prices for the bread. R determined the fair market value to be approximately 50 percent of full retail prices. Held, fair market value of P's bread contributions redetermined.
1Opinion of the Court
Nims, Judge:
Respondent determined the following deficiencies in petitioner’s Federal income tax:
TYE Deficiency
Jan. 30, 1983 $8,797,328
Feb. 3, 1985 2,175,135
Feb. 2, 1986 48,255,017
Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
This case involves a number of issues that are being handled in proceedings that are separate from the one under present consideration. In this proceeding, the parties dispute the fair market value of bakery…
2Cases cited4 opinions
- Estate of Lang v. CommissionerUnited States Tax Court · 1975
- The Estate of Grace E. Lang, Deceased. Richard E. Lang v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
- Zaentz v. CommissionerUnited States Tax Court · 1979
- Jacob J. Cooley v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
3Cited by5 opinions
- Alumax Inc. v. CommissionerUnited States Tax Court · 1997
- Alumax Inc. and Consolidated Subsidiaries v. CommissionerUnited States Tax Court · 1997
- Alumax Inc. v. CommissionerUnited States Tax Court · 1997
- Lucky Stores v. CommissionerUnited States Tax Court · 1995
- Lucky Stores, Inc. and Subsidiaries v. CommissionerUnited States Tax Court · 1995