- 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