Dayton Hudson Corporation and Subsidiaries - Page 19

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               We have recently addressed the question of what constitutes            
          a “sound accounting system” under section 1.471-(2)(d), Income              
          Tax Regs.  In Kroger Co. & Subs. v. Commissioner, T.C. Memo.                
          1997-2, we noted that section 1.471-(2)(a), Income Tax Regs.,               
          provides two specific requirements with which acceptable                    
          inventory practices must conform.  We then stated:                          
               First, such practices must conform as nearly as may be                 
               to the best accounting practice in the industry.                       
               Second, the practices must clearly reflect the                         
               taxpayer’s income.  Section 1.471-2(b), Income Tax                     
               Regs., adds consistency of application from year to                    
               year as an important and explicit element of inventory                 
               practices that clearly reflect income.  The use of the                 
               adjective “sound” in section 1.471-2(d), Income Tax                    
               Regs., does not introduce an additional standard, but                  
               only incorporates the previously articulated standards,                
               with the emphasis on the “system” or methodology                       
               employed to maintain book inventories.  * * *  [Id.]                   
          Therefore, our inquiry is, principally, whether the Divisions'              
          systems of maintaining book inventories (including the making of            
          shrinkage accruals) conform to the best accounting practice and             
          clearly reflect income.                                                     
          V.  Best Accounting Practice                                                
               The parties have stipulated that, for financial accounting             
          purposes, petitioner’s financial statements for the taxable year            
          in issue were consistent with generally accepted accounting                 
          principles (GAAP).  In Thor Power Tool Co. v. Commissioner, 439             
          U.S. 522, 532 (1979), the Supreme Court stated that the phrase              
          “best accounting practice”, as it appears in section 471(a) (and            







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