- 18 - verified by physical inventories at reasonable intervals and adjusted to conform therewith. III. Prior Proceedings Previously, on respondent's motion for summary judgment, we addressed one of the issues presented in this case. In Dayton Hudson Corp. & Subs. v. Commissioner, 101 T.C. 462 (1993), we held that section 1.471-(2)(d), Income Tax Regs., as a matter of law, does not prohibit petitioner from making a shrinkage accrual in computing book inventories. We acknowledged, however, that respondent might yet argue that petitioner's accounting system, including the making of shrinkage accruals, is not “sound” within the meaning of the regulations, or fails to clearly reflect income. Id. at 468. Respondent acknowledges our holding in the earlier opinion, but does not agree that it is correct. We adhere to that holding. IV. Are the Divisions' Systems of Accounting for Inventories, Including the Making of Shrinkage Accruals, Sound? Because the Divisions used cycle counting to conduct physical inventories of merchandise, and generally no count was taken at yearend, the Divisions necessarily had to maintain book inventory records to determine yearend inventories for purposes of computing cost of goods sold. Those book inventories included an entry for shrinkage accrual. We must determine whether those book inventories were maintained in accordance with a “sound accounting system”. Sec. 1.471-(2)(d), Income Tax Regs.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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