Dow A. and Sandra E. Huffman, et al. - Page 34

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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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