T.C. Memo. 1997-260 UNITED STATES TAX COURT DAYTON HUDSON CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21217-91. Filed June 11, 1997. P operated department stores. P used “cycle counting” to conduct physical inventories of merchandise throughout the year. P maintained book inventory records from which inventory closing balances could be determined at yearend. P estimated losses from shrinkage factors (e.g., theft and errors in billing) occurring from the time of the last physical count of inventory to yearend and made an accrual of the estimate. P calculated shrinkage accruals as a percentage of sales. Held: P's systems of maintaining book inventories do not clearly reflect income. They are, thus, not sound within the meaning of sec. 1.471-2(d), Income Tax Regs.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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