Dow A. and Sandra E. Huffman, et al. - Page 33

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          one year establishes the value of the items on hand at the                  
          beginning of the next year.  Consequently, the accountant’s error           
          would, if applied consistently (as, in fact, it was), self correct,         
          at least in the sense that, if the error were continued over the            
          life of any inventory pool, the total gain reported on account of           
          the sale of items in the pool would be correct.  See, e.g., Wayne           
          Bolt & Nut Co. v. Commissioner, 93 T.C. 500, 509 (1989) (similar            
          conclusion with respect to the income reported through the period           
          in which ending inventory is correctly valued).  The accountant’s           
          error was, thus, an error in timing.  Because it was an error in            
          the proper time for reporting an item of income (gain from sales),          
          the accountant’s method was a material item in each member’s                
          overall plan of accounting.  See sec. 1.446-1(e)(2)(ii)(a), Income          
          Tax Regs.  On that ground alone, respondent’s change to that method         
          would appear to be a change in a method of accounting, as that              
          expression is used in section 1.446-1(e)(2)(ii)(a), Income Tax              
          Regs.  By consistently repeating the same error, the accountant             
          established a pattern, which (although not determinative of) is             
          indicative of a method of accounting.  Id.                                  
               Nevertheless, section 1.446-1(e)(2)(ii)(b), Income Tax Regs.,          
          provides that a change in method of accounting does not include             
          correction of mathematical or posting errors, and petitioners argue         
          that, in correcting the accountant’s error, respondent did no more          
          than correct a mathematical or posting error.  We have interpreted          






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