Dow A. and Sandra E. Huffman, et al. - Page 42

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          States, 209 Ct. Cl. 559, 532 F.2d 1352 (1976), to support their             
          position that respondent merely corrected mathematical errors and           
          there were no accounting method changes.  In Korn Indus., Inc. for          
          4 consecutive years, the taxpayer, a furniture manufacturer,                
          deviated from its long-established method of valuing inventories.           
          For those 4 years, the taxpayer improperly omitted certain costs            
          from the value of its finished goods inventory, which caused a              
          correspondingly improper addition to the cost of goods sold and,            
          thus, an understatement of gross income.  On its tax return for the         
          fifth year, the taxpayer showed a correct beginning inventory,              
          which included costs that had been omitted from the previous year’s         
          ending inventory.  The taxpayer viewed its action as the correction         
          of an error and not a change in its method of accounting.                   
          Therefore, it accepted the Commissioner’s adjustments to its                
          beginning and ending inventories for the 2 preceding years (for             
          which the period of limitations on assessment and collection had            
          not run), but it objected to the Commissioner’s section 481                 
          adjustment, which the Commissioner made to account for the                  
          disparity between the taxpayer’s opening inventory for the second           
          preceding year and its ending inventory for the third preceding             
          year (which could not be adjusted since the period of limitations           
          had run).  If the taxpayer were right, that its method of                   
          accounting had not changed, it would enjoy, in effect, a double             
          deduction, to the extent of the costs improperly omitted from               






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