T.C. Memo. 1997-2 UNITED STATES TAX COURT THE KROGER COMPANY AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3358-94. Filed January 2, 1997. P operated supermarkets and convenience stores. P used “cycle counting” to conduct physical inventories of merchandise throughout the year. P maintained book inventory records from which inventory closing balances could be determined at year’s end. P estimated losses from shrinkage factors (e.g., theft and errors in billing) occurring from the time of the last physical count of inventory to year’s end and made an accrual of the estimate. P calculated shrinkage accruals as a percentage of gross sales. Held: P’s systems of maintaining book inventories (including the making of shrinkage accruals) conform to the best accounting practice and clearly reflect income. They are, thus, sound within the meaning of sec. 1.471-2(d), Income Tax Regs.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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