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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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