- 38 - respondent's method violates the principle of annual accounting. Of course, under the retailers’ shrinkage method, the retailers’ estimates of shrinkage accruals are also based on information gathered from prior years, since the retailers’ shrinkage rates are dependent, in part, on historical data. The distinction, however, is that the retailers’ shrinkage method utilizes prior year information as a factor in calculating the current year’s shrinkage rate, whereas respondent’s method plainly substitutes yearend shrinkage of the prior year for yearend shrinkage of the taxable year. If physical inventories were required to be taken at year's end, taxable year shrinkage would be known with certainty, and no estimate of yearend shrinkage would be necessary. Physical inventories, however, are not required to be taken at year's end. Sec. 1.471-2(d), Income Tax Regs. Once the Secretary decided not to require physical inventories at year’s end, see Dayton Hudson Corp. & Subs. v. Commissioner, 101 T.C. at 467; sec. 1.471-2(d), Income Tax Regs., and taxpayers began to exercise the privilege of computing yearend inventories from book inventory records, estimations of yearend shrinkage became inescapable, whether the method of estimating yearend shrinkage involves calculation (the retailers' shrinkage method) or substitution (respondent's method). Respondent recognizes that fact. Respondent's position, however, is that, unless a taxpayer can demonstrate the accuracy of his calculation of yearend shrinkage, the taxpayerPage: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
Last modified: May 25, 2011