Dow A. and Sandra E. Huffman, et al. - Page 36

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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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