- 29 - accepted standard for a trade or industry may be established by reference to a common practice followed by members of that trade or industry. See sec. 1.471-2(a)(1), Income Tax Regs. (inventories must conform to the best accounting practice in the trade or business). Petitioners' methodology for estimating stub period shrinkage is consistent with and comparable to the best practice used in the retail industry. Like most major retailers, petitioners use cycle counting, which is widely accepted in the retail industry. Petitioners' physical inventory process is strictly and carefully conducted and reviewed by independent counting services, petitioners' internal auditors and loss prevention department, and independent auditors. Petitioners' competitors also estimate shrinkage as a percentage of sales. Estimating shrinkage for the stub period as a percentage of sales is the best practice available in the industry. It is also relevant that petitioners used the same shrinkage estimates for reports issued to the Securities Exchange Commission. We conclude that petitioners' method of accounting for their inventories, including their estimates of shrinkage at yearend, conforms as nearly as may be to the best accounting practice in the trade or business. We so hold, and we turn to the second prong. III. Clear Reflection of Income Inventory accounting is governed by sections 446 and 471. Section 471 prescribes the general rule for inventories. ThePage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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