- 33 - 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 interpretedPage: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
Last modified: May 25, 2011