- 10 - mistakes were not an unauthorized change of accounting method, but more “akin to posting errors”. Id. at 885. Similarly, in Korn Indus., the court held that where a taxpayer inadvertently forgot to include several categories of costs in calculating its finished goods inventory, the subsequent inclusion was not an accounting method change. As the court explained, the taxpayer “did not change to any different method.” Id. at 1355. Our reasoning in Wayne Bolt & Nut Co. v. Commissioner, supra, is more illustrative of Color Arts’s situation. For numerous years before 1982, the taxpayer calculated its opening and ending inventory using a “seriously flawed” perpetual inventory record-keeping system. Id. at 508. Historically, the taxpayer verified inventory by taking a partial physical inventory. In 1982, the taxpayer performed a complete physical inventory which indicated that opening inventory for fiscal 1982 was 10 times greater than ending inventory reflected on the books and as originally reported for the end of the prior fiscal year. For its 1982 fiscal year, the taxpayer reconstructed its opening and ending inventory on the basis of the results of the complete inventory. We held that “Since * * * [the taxpayer’s] pre-1982 method of determining inventory involved the proper time for reporting income, it was a ‘material item’” and that the taxpayer’s “change from a seriously flawed and disorganized method of determining inventory to a method of determining bothPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011