Dayton Hudson Corp. v. Commissioner
United States Tax Court
P, a publicly held corporation primarily engaged in retailing, uses an estimate of shrinkage not verified by yearend physical count in computing its yearend inventory. R argues that the use of such estimate is prohibited by sec. 1.471-2(d), Income Tax Regs. (the regulation). Thus, R argues that P's use of such estimate causes its accounting method, as a matter of law, to fail clearly to reflect income.
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P, a publicly held corporation primarily engaged in retailing, uses an estimate of shrinkage not verified by yearend physical count in computing its yearend inventory. R argues that the use of such estimate is prohibited by sec. 1.471-2(d), Income Tax Regs. (the regulation). Thus, R argues that P's use of such estimate causes its accounting method, as a matter of law, to fail clearly to reflect income. P objects to R's motion for summary judgment on the ground that the regulation does not prohibit the estimate at issue, and that whether its accounting method clearly reflects income therefore…
1Opinion of the Court
Dayton Hudson Corporation and Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent
Dayton Hudson Corp. v. Commissioner
Docket No. 21217-91
United States Tax Court
101 T.C. 462; 1993 U.S. Tax Ct. LEXIS 71; 101 T.C. No. 30;
November 18, 1993, Filed
An order denying respondent's motion for summary judgment will be issued.
P, a publicly held corporation primarily engaged in retailing, uses an estimate of shrinkage not verified by yearend physical count in computing its yearend inventory. R argues that the use of such estimate is prohibited by sec. 1.471-2(d), Income Tax Regs. (the…
Also in this document: Dissent · Colvin; Concurrence; Dissent · Gerber.
2Cases cited7 opinions
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Brown v. HelveringSupreme Court of the United States · 1934
- Espinoza v. CommissionerUnited States Tax Court · 1982
- Thor Power Tool Co. v. CommissionerUnited States Tax Court · 1975
- Hamilton Industries, Inc. v. CommissionerUnited States Tax Court · 1991
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