Dayton Hudson Corporation and Subsidiaries - Page 21

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               is incurred, and generally is taken into account for                   
               Federal income tax purposes, in the taxable year in                    
               which all the events have occurred that establish the                  
               fact of the liability, the amount of the liability can                 
               be determined with reasonable accuracy, and economic                   
               performance has occurred with respect to the liability.                
               * * *                                                                  
          The term “liability”, as used in section 1.446-1(c)(1)(ii)(A),              
          Income Tax Regs., is defined in section 1.446-1(c)(1)(ii)(B),               
          Income Tax Regs., to include “a cost taken into account in                  
          computing cost of goods sold”.                                              
               Notwithstanding the latitude generally enjoyed by a taxpayer           
          in selecting a method of accounting, where inventories are                  
          employed, accrual accounting is the general rule to account for             
          purchases and sales:                                                        
               Where inventories are employed, purchases and sales                    
               must be computed on the accrual method (unless another                 
               method is authorized by the Commissioner) in order to                  
               avoid the distortion of income.  Sec. 1.446-1(c)(2),                   
               Income Tax Regs.; Stoller v. United States, 162 Ct. Cl.                
               839, 845, 320 F.2d 340, 343 (1963).                                    
          Molsen v. Commissioner, 85 T.C. 485, 499 (1985).                            
               In any event, a taxpayer’s right to adopt a method of                  
          accounting is subject to the requirement that the method must               
          clearly reflect income.  Section 446(b) states that, if the                 
          method adopted “does not clearly reflect income, the computation            
          of taxable income shall be made under such method as, in the                
          opinion of the Secretary, does clearly reflect income.”  See also           
          sec. 1.446-1(c)(1)(ii)(C), Income Tax Regs.                                 







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Last modified: May 25, 2011