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of error no more lends itself to being classified as an
arithmetical (mathematical) error than does the error of the baker
who, having intended to double the recipe for a cake he has baked,
finds that the cake has only risen half way because he failed to
double the measure of baking powder called for by the recipe.
Petitioners cannot avoid respondent’s section 481 adjustment on the
ground that respondent changed no method of accounting because he
corrected only mathematical or posting errors.
Nor can petitioners avail themselves of the exceptions in
section 1.446-1(e)(2)(ii)(b), Income Tax Regs., specifying that an
accounting method change does not include the correction of errors
in the computation of tax liability or adjustments not involving
the proper time for inclusion of an item of income or the taking of
a deduction.
Although section 1.446-1(e)(2)(ii), Income Tax Regs., appears
dispositive in respondent’s favor, our inquiry does not end there,
because courts addressing the issue of whether a change in method
of accounting has occurred have not uniformly given consistency and
timing considerations the weight given those considerations by the
regulations.
C. Caselaw
1. Introduction
In considering the caselaw dealing with what constitutes a
change in method of accounting, we must distinguish between cases
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