Dayton Hudson Corporation and Subsidiaries - Page 37

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                    5.  Dr. Seago's Criticism of Respondent's Method                  
               Dr. Seago states that the shortcomings of respondent's                 
          method are that (1) the loss for the taxable year is dependent on           
          the date of the physical inventories and (2) losses actually                
          attributable to a prior taxable year are included in the loss for           
          the current year and losses attributable to the current taxable             
          year are deducted in the following taxable year.  Dr. Seago                 
          asserts that respondent's method contains a systematic bias                 
          towards understating losses when sales are increasing.                      
               F.  Respondent's Expert Testimony                                      
                    1.  Introduction                                                  
               Respondent presents the testimony of two experts, Dennis J.            
          Gaffney, Ph.D., a professor of accounting at the University of              
          Toledo, and David W. LaRue, Ph.D., an associate professor of                
          commerce at the University of Virginia.                                     
                    2.  Dr. Gaffney                                                   
               Dr. Gaffney was requested to render an opinion as to whether           
          the Divisions' shrinkage methods were appropriate for financial             
          accounting and reporting purposes and, if so, the degree of error           
          in estimating shrinkage that could be tolerated for those                   
          purposes.  Although Dr. Gaffney's opinions on those issues are              
          not relevant with respect to the issue of clear reflection of               
          income for tax purposes, we believe that Dr. Gaffney's comparison           
          of Target's verified and accrued shrinkage in retail sales                  






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