Dow A. and Sandra E. Huffman, et al. - Page 41

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          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. United                






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