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Charles Fassler, Mark F. Sommer, Jennifer S. Smart, and
Brett S. Gumlaw, for petitioners.
Mark D. Eblen, for respondent.
OPINION
HALPERN, Judge: These cases have been consolidated for
purposes of trial, briefing, and opinion. By notices of
deficiency dated December 19, 2003 (the notices), respondent
determined deficiencies in Federal income taxes as follows:
Taxable (Calendar) Year
Deficiency
Petitioners (Husband and Wife) 1997 1998 1999
Dow A. and Sandra E. Huffman -- $36,757 $9,413
James A. and Dorothy A. Patterson -- 35,542 --
Douglas M. and Kimberlee H. Wolford -- 33,422 1,966
Neil A. and Ethel M. Huffman $131,408 535,065 304,033
Petitioners have conceded some of the adjustments made by
respondent that give rise to the deficiencies in question, and
other adjustments are merely computational and do not require our
attention. The sole issue for decision is whether a correction
to the inventory method employed by corporations owned by certain
of the petitioners constitutes an accounting method change that
requires an adjustment pursuant to section 481 of the Internal
Revenue Code of 1986, as amended and in effect for the years in
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