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the term “posting error” to be an error in “‘the act of
transferring an original entry to a ledger’”. Wayne Bolt & Nut
Co., v. Commissioner, supra at 510-511 (quoting Black’s Law
Dictionary 1050 (5th ed. 1979)). That does not describe the
accountant’s error, and we conclude that the accountant made no
posting error. The term “mathematical error” is not, as stated,
defined in the regulation, nor have we or any other court defined
it for purposes of section 1.446-1(e)(2)(ii)(b), Income Tax Regs.
The term does, however, appear in the Internal Revenue Code,
principally in section 6213(b), which allows the unrestricted
assessment and collection of tax arising out of mathematical or
clerical errors. For purposes of section 6213, the term
“mathematical or clerical error” is defined by section 6213(g)(2).
As pertinent to this case, the definition is “an error in addition,
subtraction, multiplication, or division”. Sec. 6213(g)(2)(A).
Moreover, before Congress provided the specific definition of the
term “mathematical or clerical error” found in section 6213(g),
Courts generally had limited the scope of the term “mathematical
error” for purposes of section 6213(b) and its predecessors to
errors in arithmetic. E.g., Farley v. Scanlon, 13 AFTR 2d 932,
933, 64-1 USTC par. 9371 (E.D. N.Y. 1964) (mathematical error
“means an error in computing the tax on what the return itself
concedes to be income”); Repetti v. Jamison, 131 F. Supp. 626, 628
(N.D. Cal. 1955) (“the term * * * was meant to refer to errors in
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