- 5 - determined that petitioners' ending inventories as reported understated their taxable income by the following amounts:2 Taxable Year Understatement 1983 $24,276,994 1984 7,837,122 1985 20,394,840 1986 1,196,045 The shrinkage disallowed by respondent relates to the period of time referred to by the parties as the "stub period". In general, the stub period is the time between the date of the last physical inventory prior to the taxable yearend and the taxable yearend. In some cases, Wal-Mart took a physical inventory in January and booked the inventory in February of the next year. In those cases, the stub period is the time between the date of the physical inventory immediately prior to the January physical inventory and the taxable yearend. In other cases, Wal-Mart booked two consecutive January inventories in February. In those cases, the stub period is the time between the first January inventory and the taxable yearend following the second January inventory. In the case of a new store for which a physical inventory was not taken before the taxable yearend, the stub period is the period beginning with the date of the store opening and ending with the taxable yearend. 2 Respondent also determined that part of these understatements stemmed from petitioners' miscalculation of a cost complement. The parties have settled their disagreements with respect to this calculation, and it is not at issue herein.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011