- 41 - inventory to a correct method involves only timing questions and, thus, constitutes a change in method of accounting. See, e.g., Superior Coach, Inc. v. Commissioner, 80 T.C. at 910; Wayne Bolt & Nut Co. v. Commissioner, 93 T.C. at 511. Because the accountant’s error in the instant case had precisely the same effect as did the taxpayer’s discounting practices in Primo Pants Co.--viz, it served merely to alter the distribution of a lifetime income among taxable periods--that case would seem to govern us here, requiring us to conclude that respondent’s adjustments to the members’ inventories constituted a change in the members’ methods of accounting. Petitioners attempt to distinguish Primo Pants Co. and the cases of the Court that follow it, but their reading of those cases is flawed. For example, on brief, petitioners discount the relevance of our holding in Primo Pants Co. because, they suggest: “No contention was made that the undervalued inventory was the result of a mathematical error.” On the contrary, our report in Primo Pants Co. states: “Petitioner characterizes the various adjustments to inventory as the mere correction of its application of its lower of cost or market method of valuing inventory.” Primo Pants Co. v. Commissioner, 78 T.C. at 714. b. Cases Cited by Petitioners i. Korn Indus., Inc. v. United States Petitioners rely heavily on Korn Indus., Inc. v. UnitedPage: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Next
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