If using a cutoff basis, the change applies only to the computation of ending inventories
after the beginning of the year of change.
In order to calculate Required Production, we need to first calculate Beginning and Ending Inventories
for each quarter.
The preamble indicates that the intention of the proposed regulations is that neither sales-based royalties nor sales-based vendor allowances should adjust the value of ending inventories
. The IRS will not challenge taxpayers applying methodologies similar to those described in the proposed regulations, as evidenced in LB&I 4-0211-002.
After a lengthy analysis of the history and application of the retail method, the IRS ruled that the method will correctly compute inventories at retail lower-of-cost-or-market (LCM), only if the merchant uses contemporaneous retail prices when computing the cost complement and ending inventories (at retail).
The merchant must also be able to show that it used the data properly when computing the cost complement, ending inventories (at retail) and retail LCM (or retail cost).
In the past year, the Tax Court has rendered three opinions on the use of shrinkage estimation when accounting for ending inventories
using the perpetual method (Wal-Mart Stores, Inc., TC Memo 1997-1; The Kroger Co., TC Memo 1997-2; Dayton Hudson Corp., TC Memo 1997-260).
This method of accounting assumes that the goods most recently purchased or produced are the first goods sold and, accordingly, that their associated costs are the first costs treated as costs of sale, Thus, inventory basis is built up in layers over time as ending inventories
periodically increase over beginning inventories.
On discovery, the taxpayer corrected its mistake by adjusting both the beginning and ending inventories
. The Service took the position that this was a change in accounting method, the correction of which would cause a Sec.