Dayton Hudson Corporation and Subsidiaries - Page 20

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          section 1.471-2(a), Income Tax Regs.), is synonymous with GAAP.             
          Petitioner followed the same accounting practices for both                  
          Federal income tax and financial reporting purposes.  We find,              
          therefore, that the Divisions' systems of maintaining book                  
          inventories conform to the best accounting practice within the              
          meaning of section 471(a) and section 1.471-2(a), Income Tax                
          Regs.                                                                       
          VI.  Clear Reflection of Income                                             
               A.  Methods of Accounting and the Legal Requirement of                 
          Clear Reflection of Income                                                  
               The general rule for methods of accounting is set forth in             
          section 446(a):                                                             
               Taxable income shall be computed under the method of                   
               accounting on the basis of which the taxpayer regularly                
               computes his income in keeping his books.                              
          A taxpayer has latitude, however, in selecting a method of                  
          accounting.  Section 1.446-1(a)(2), Income Tax Regs., provides:             
               It is recognized that no uniform method of accounting                  
               can be prescribed for all taxpayers.  Each taxpayer                    
               shall adopt such forms and systems as are, in his                      
               judgment, best suited to his needs.  * * *                             
               The accrual method is a permissible method of accounting.              
          Sec. 446(c).  Section 1.446-1(c)(1)(ii)(A), Income Tax Regs.,               
          provides:                                                                   
               Generally, under an accrual method, income is to be                    
               included for the taxable year when all the events have                 
               occurred that fix the right to receive the income and                  
               the amount of the income can be determined with                        
               reasonable accuracy.  Under such a method, a liability                 






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