Dayton Hudson Corporation and Subsidiaries - Page 18

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               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.                    




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