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DAYTON HUDSON CORP. & SUBSIDIARIES v. COMMISSIONER

Docket No. 21217-91.

101 T.C. 462 (1993)

DAYTON HUDSON CORPORATION AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 18, 1993.

Attorney(s) appearing for the Case

David R. Brennan, John K. Steffen, and Walter A. Pickhardt, for petitioner.

John C. Schmittdiel, for respondent.

OPINION

HALPERN, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the year ended January 28, 1984, based upon her determination that petitioner improperly computed ending inventory. Respondent moves for summary judgment that section 1.471-2(d), Income Tax Regs. (the regulation), prohibits certain adjustments to ending inventory made by petitioner. Specifically, respondent argues that the regulation prohibits petitioner...

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