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arithmetic. This opinion is based primarily on the common meaning
given to the phrase ‘mathematical error,’”). We have no reason to
believe that the drafters of section 1.446-1(e)(2)(ii)(b), Income
Tax Regs., intended the term “mathematical error” to have any
meaning beyond its common meaning, and petitioners have failed to
show us that the term has a common meaning different from the
common meaning found by the District Court in Repetti; i.e., an
error in arithmetic. That definition comports with the scope of
the term “posting error”, with which the term “mathematical error”
is associated in the regulations, and we conclude that the term
“mathematical error”, as used in section 1.446-1(e)(2)(ii)(b),
Income Tax Regs., describes an error in arithmetic; i.e., an error
in addition, subtraction, multiplication, or division.
The accountant did not make a mathematical error because he
did not make an error in arithmetic. He neither divided when he
should have multiplied nor multiplied 2 x 2 and found the product
to be 5. The accountant erred in that, after deflating the
current-year cost of each inventory pool to determine whether, at
base-year costs, there had been an increment in the pool, and
finding an increment, he failed to multiply the increment by the
cumulative index in order to determine the yearend LIFO value of
the pool. The accountant reached an erroneous result not because
he made a mistake in arithmetic (multiplication) but because he
omitted the critical step of multiplication altogether. That kind
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