Color Arts, Inc., John P. Csepella, A Person Other Than The Tax Matters Person - Page 10




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          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 both             






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