The Kroger Company and Subsidiaries - Page 36

                                               - 36 -                                                 
            identical to the amount of yearend shrinkage for the previous                             
            year, respondent’s method would produce only an estimate of the                           
            loss from shrinkage factors for the taxable year.  The facts                              
            underlying that conclusion can be illustrated by the following                            
            diagram, in which it is assumed that a physical inventory is                              
            taken semiannually, on March 31 and September 30, and that the                            
            taxpayer is a calendar year taxpayer.                                                     


                         1995 Taxable Year  1996 Taxable Year   1997 Taxable Year                     
                        Dec. 31                   Dec. 31                   Dec. 31                  

                   1995 Inventory Year1996 Inventory Year 1997 Inventory Year                         
           Sept.30 Mar. 31  Sept. 30  Mar. 31   Sept. 30  Mar. 31    Sept. 30                         

            Under respondent’s method, the taxpayer’s cost of goods sold for                          
            a taxable year would be computed by including shrinkage for the                           
            taxpayer’s inventory year ending September 30.  Shrinkage for the                         
            inventory year might equal taxable year shrinkage, but the                                
            occurrence of this remote possibility is impossible to verify.                            
            What is likely (almost a certainty) is that the taxpayer,                                 
            computing his cost of goods sold under respondent's method, would                         
            be making that computation using some figure for taxable year                             
            shrinkage that was not the actual taxable year shrinkage.  In                             
            other words, the taxpayer would be forced to use what is almost                           
            certainly no more than an estimate of taxable year shrinkage in                           
            computing cost of goods sold.                                                             





Page:  Previous  26  27  28  29  30  31  32  33  34  35  36  37  38  39  40  41  42  43  44  45  Next

Last modified: May 25, 2011