- 19 - 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) (andPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011