Dayton Hudson Corporation and Subsidiaries - Page 7

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          cycle counting is used, and the cycle for a particular store does           
          not end on the last day of the year, then losses from shrinkage             
          factors for the physical-to-yearend period (yearend shrinkage)              
          must be estimated if such yearend shrinkage is to be taken into             
          account.                                                                    
               Petitioner maintained a “Controller's Manual” containing a             
          standard control procedure to set forth corporate policy for                
          accounting for inventory shrinkage and for planning and reporting           
          physical inventory results.  That manual provided that all                  
          companies must take at least one complete physical inventory a              
          year.  It further provided that “[e]ach Operating Company                   
          Controller is responsible for accounting for inventory shrinkage            
          in accordance with the accrual basis of accounting.”  The manual            
          defined the term “inventory shrinkage accrual rate” as “[t]he               
          rate at which inventory is written off to cost of sales to                  
          provide for inventory shrinkage.  The rate is stated as a                   
          percentage of net sales.”  The manual further provided for the              
          adjustment of physical inventory results as follows:                        
               When physical inventory shortage is less than the                      
               provision [i.e., the accrual] for inventory shrinkage,                 
               cost of sales should be reduced for the calculated                     
               difference between the physical inventory shortage and                 
               the provision for inventory shrinkage.                                 
               When physical inventory shortage is more than the                      
               provision for inventory shrinkage, cost of sales should                
               be increased for the calculated difference between the                 
               physical inventory shortage and the provision for                      
               inventory shrinkage.                                                   






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