- 33 - 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.Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
Last modified: May 25, 2011