- 24 - Commissioner determines that a taxpayer's method of accounting does not clearly reflect income, the taxpayer must demonstrate either that his method of accounting clearly reflects income or that the Commissioner's method does not clearly reflect income. See Asphalt Prods. Co. v. Commissioner, supra at 847; Kroger Co. & Subs. v. Commissioner, T.C. Memo. 1997-2. C. The Divisions' Shrinkage Methods The Divisions maintained book inventory records from which yearend inventories could be determined. Losses for the taxable year occasioned by shrinkage factors (taxable year shrinkage) were reflected in the Divisions' book inventory records under methods (individually, Target's shrinkage method and Dayton's shrinkage method; together, when no distinction is intended, the Divisions' shrinkage methods) that essentially involved three variables: (1) an estimate of losses from shrinkage factors for the portion of the taxable year preceding the date of the physical inventory (preinventory accrual), (2) the accrual error (a measure of error in both the prior year's shrinkage accrual and the preinventory accrual), and (3) the shrinkage accrual for the taxable year. Target accounted for shrinkage as a percentage of sales using rates (accrual rates) that were set for each department in each store for each taxable year. Those rates were derived from a companywide accrual rate that was based on a combination of factors including historical shrinkage experience, demographics,Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
Last modified: May 25, 2011