- 18 - Petitioner next relies on another provision of the same regulation, which states: “A change in method of accounting does not include correction of mathematical or posting errors, or errors in the computation of tax liability”. Sec. 1.446- 1(e)(2)(ii)(b), Income Tax Regs. Petitioner argues that the accounting treatment of the deposits was not a method of accounting but mere error, relying on Korn Indus., Inc. v. United States, 209 Ct. Cl. 559, 532 F.2d 1352 (1976). In Korn Indus., the taxpayer manufactured furniture. The taxpayer used separate inventories for raw materials, work-in-process, supplies, and finished goods. There were 14 kinds of material in the finished furniture; e.g., lumber, mirrors, glue, nails. During the years in issue, 3 of the 14 materials costs had not been included in the finished goods inventory, although they were included in the other three inventories. When the taxpayer later took account of the three materials costs, the Government claimed there was a change in accounting method, but the court found that the taxpayer had merely corrected an error. In the instant case, petitioner’s “mistakes” are much more egregious and of a different nature. In 1992, petitioner reported gross receipts from his business as a bail bondsman of $80,456, and increased the balances in his three accounts by a combined total of $90,727. In 1993, petitioner reported gross receipts from his business as a bail bondsman of $100,467 and increased thePage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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