- 12 - following the year of opening. In most cases, Target set accrual rates for new stores by considering the average shrinkage rate for the district in which the new store was being opened. Target also considered the demographics of that district, as well as the marketing plan of “sister stores”--stores that are located in areas with similar demographics and have merchandise mixes similar to that anticipated for the new store--in setting accrual rates for new stores. 3. Warehouses During 1979 through 1984, physical inventories were performed at Target's distribution centers and metro warehouses (hereafter, collectively referred to as “warehouses”) once each year prior to the close of the taxable year, during the months of December or January. The results of the physical inventories at the warehouses were taken into account in April of the subsequent taxable year on a departmental basis by the Target stores serviced by each particular warehouse. The amount of shrinkage was allocated to the Target stores based upon the store's use of a particular warehouse. That practice reflected the determination that the warehouses' shrinkage generally reflected billing errors to stores. C. Proposed Deficiencies With Respect to Target In the notice of deficiency, respondent disallowed shrinkage accruals for 1984. The LIFO cost adjustment was $36,339,217,Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011