Dayton Hudson Corporation and Subsidiaries - Page 26

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               D.  Respondent's Method                                                
               Respondent would permit the Divisions to account for losses            
          from shrinkage factors only when such losses are verified by                
          physical inventories (respondent's method).  Respondent claims              
          that that “method is nothing more than application of the                   
          principle that taxpayers may not reduce income by unverified                
          losses or expenditures, or unreliable estimates”.  Upon closer              
          analysis, we conclude that respondent's method essentially                  
          estimates yearend shrinkage for the taxable year based on yearend           
          shrinkage for the prior taxable year.                                       
               Respondent's method would adjust the Divisions' book                   
          inventories by disallowing any shrinkage accrual.  The Divisions'           
          cost of goods sold, as determined by book inventories, would                
          essentially include shrinkage for inventory cycles beginning in             
          the prior taxable year and ending in the taxable year and not any           
          portion of the shrinkage determined for inventory cycles                    
          beginning within the taxable year and ending in the next taxable            
          year (i.e., yearend shrinkage).  In sum, the Divisions’ cost of             
          goods sold for a taxable year that included cross-year inventory            
          cycles would include shrinkage accurately measured (i.e.,                   
          verifiable) for some period other than that taxable year (i.e.,             
          an inventory year).                                                         
               If it is assumed that there is yearend shrinkage, then,                
          unless the amount of yearend shrinkage for the taxable year is              
          identical to the amount of yearend shrinkage for the previous               




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