- 26 - 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 previousPage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
Last modified: May 25, 2011