Wal-Mart Stores, Inc. and Subsidiaries - Page 37

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          Dr. Fienberg's testimony to argue that such a relationship does             
          not exist.  We do not find this testimony to be persuasive.  We             
          read the record to support a finding of a relationship between              
          shrinkage and sales under which a store's shrinkage will increase           
          or decrease in accordance with its sales.  An increase in sales,            
          for example, results in an increase in purchases, and, as                   
          purchases rise, so do the goods lost in shipment or through                 
          paperwork errors.  An increase in sales results in more inventory           
          being placed on the shelves for sale, and, as the shelf inventory           
          increases, so do the goods lost through breakage, theft, and                
          erroneous price changes.  An increase in sales results in greater           
          customer traffic in the store, and, as more customers enter the             
          store, the ratio of sales personnel to customers declines, making           
          it more difficult to detect theft.  An increase in sales results            
          in the employment of additional sales personnel, and, as sales              
          personnel increase, so does employee theft.                                 
                With this relationship in mind, we find that the                      
          reasonableness of petitioners' shrinkage estimates is seen                  
          further by comparing:  (1) The retail value of shrinkage                    
          estimates for the stub period to the verified shrinkage for the             
          same period and (2) the individual stub period estimates to the             
          shrinkage that was attributable to the stub period and that was             
          verified by a physical count in the next year.9  The verified               

               9 We compare the following year's physical inventory because           
          stub period shrinkage is verified through physical inventories              
                                                             (continued...)           



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