- 37 - Respondent does not seriously claim that losses from shrinkage factors in a cross-year inventory cycle occur only in the latter year. Nor does respondent claim that losses from shrinkage factors do not occur generally throughout an inventory cycle. On the record before us, we have no doubt that, on a regular basis, the retailers experienced losses from theft, billing errors, and other shrinkage factors. We also have no doubt that some of those losses were experienced during the physical-to-yearend period and gave rise to yearend shrinkage. Therefore, the principal difference between the retailers’ shrinkage method and respondent’s method is that respondent, without admitting it, accepts an estimate of yearend shrinkage while the retailers, by making a shrinkage accrual, consciously attempt to estimate that shrinkage. H. Annual Accounting It is well settled that the Federal income tax system is based on annual accounting. E.g., Heiner v. Mellon, 304 U.S. 271, 275 (1938). "Inventories are intended to insure a clear reflection of the year's income by matching sales during the taxable year with the costs attributable to those sales". Rotolo v. Commissioner, 88 T.C. 1500, 1515 (1987). Respondent's method, in effect, substitutes yearend shrinkage of the prior year for yearend shrinkage of the taxable year. Sales during the taxable year are matched with losses verified to be both losses for that year and losses for the end of the prior year. On its face,Page: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Next
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