Wal-Mart Stores, Inc. and Subsidiaries - Page 5

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          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.            




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