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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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