Dayton Hudson Corporation and Subsidiaries - Page 24

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          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,            




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