Dayton Hudson Corporation and Subsidiaries - Page 33

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          years, and an accrual error is detected, some portion of that               
          error is attributable to each of the taxable years.  With support           
          from the results of the 10-year correlation analysis, Dr. Seago             
          assumed that sales and shrinkage were perfectly correlated                  
          throughout the year and, thus, determined that any accrual error            
          should be allocated according to the relative sales between the             
          two relevant taxable years to arrive at a figure for taxable year           
          shrinkage.  Dr. Seago examined Target's sales figures for the               
          taxable years ending in 1984, 1985, and 1986, and determined that           
          approximately 75 percent of sales between physical inventory                
          dates are allocable to the taxable year prior to the taxable year           
          in which the physical inventory is taken.  As a result, Dr. Seago           
          allocated 75 percent of the applicable accrual error to the                 
          taxable year prior to the taxable year in which the physical                
          inventory was taken and 25 percent to the taxable year in which             
          the physical inventory was taken.  Dr. Seago compared his                   
          resulting figures for taxable year shrinkage (sales-allocated               
          taxable year shrinkage) with the shrinkage claimed by Target for            
          tax purposes and the shrinkage that would be allowed under                  
          respondent's method.  Dr. Seago's analysis produced the following           
          results:5                                                                   


          5    These tables contain a few minor computational errors, and             
          we have taken the liberty of calculating the aggregate percentage           
          difference using Dr. Seago's numbers.                                       





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