Dayton Hudson Corporation and Subsidiaries - Page 48

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            present purposes, as a measure of the degree to which two                                    
            variable, but consistently constituted, quantities tend to change                            
            with respect to each other and not as a measure of the degree to                             
            which two inconsistently constituted quantities change with                                  
            respect to each other.  Essentially, Dr. Seago has not persuaded                             
            this Court that the strong correlation between sales and                                     
            shrinkage derived from the 10-year correlation analysis is the                               
            product of the true relationship between sales and shrinkage and                             
            not the product of the confluence of varying LIFO pool                                       
            attributes.  Dr. Seago has failed to explain that apparently                                 
            fundamental flaw in the 10-year correlation analysis.  That is                               
            not to say that we would never accept statistical analyses                                   
            demonstrating a correlation between sales and shrinkage; that is                             
            only to say that Dr. Seago, in this case, has simply failed to                               
            prove the significance of the correlation derived from the                                   
            10-year correlation analysis.9  Dr. Seago recognizes that an                                 

            9     It should be noted that, in Kroger Co. & Subs. v.                                      
            Commissioner, T.C. Memo. 1997-2, we stated:                                                  
                  Although we accept Dr. Bates' opinion as to the                                        
                  correlation between sales and shrinkage at the business                                
                  level, and we are impressed by Dr. Bates' sales-based                                  
                  accuracy analysis, we are hesitant to rest our                                         
                  conclusion as to the accuracy of the retailers'                                        
                  shrinkage method on a correlation whose significance we                                
                  may not fully appreciate.  * * *                                                       
            Similarly, in this case, although we accept Dr. Seago's opinion                              
            that the data he examined in the 10-year correlation analysis                                
            revealed a strong correlation, Dr. Seago has not demonstrated the                            
                                                                           (continued...)                





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