- 50 - assumption that sales and shrinkage are sufficiently correlated so that the sum of aggregate monthly shrinkage accrued as a percentage of sales for the taxable year, adjusted for an allocation of any accrual error based on a ratio of relative sales between the relevant taxable years, yields a figure for taxable year shrinkage that would clearly reflect income.10 Although we believe that sales have some value as a predictor of shrinkage at the Target-wide level, we simply cannot accept the critical assumption that underlies Dr. Seago's shrinkage accrual accuracy analysis. Dr. Seago did not conduct an analysis of the correlation between sales and shrinkage or a shrinkage accrual accuracy analysis for data derived from the operations of Dayton’s. We assume that petitioner wishes that we infer both a strong correlation between sales and shrinkage and a favorable shrinkage 10 In addition, this Court has difficulty with Dr. Seago's shrinkage accrual accuracy analysis for other reasons. Target's shrinkage method results in the accrual of shrinkage based on a rate set at the beginning of the taxable year for each department within each store. Thus, conceivably, a department within a store could accrue shrinkage at two different rates during the cross-year inventory period, e.g., 2 percent of sales during the taxable year's physical-to-yearend period and 2.5 percent of sales during the period prior to the physical inventory in the next taxable year. An allocation of any accrual error only, as opposed to an allocation of total verified shrinkage, is inconsistent with the underlying assumption that sales and shrinkage are perfectly correlated. In the same vein, Dr. Seago allocates accrual error based on a 75/25 ratio that is an approximation of the relative sales between the relevant taxable years and not the actual cross-year sales percentages.Page: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Next
Last modified: May 25, 2011