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inventory in the first 2 years. The Court of Claims conceded that
the taxpayer had not properly accounted for the omitted costs.
Nevertheless, it agreed with the taxpayer that, in revaluing its
finished goods inventory for the first open year, the Commissioner
had not changed its method of accounting. Id. at 1356. The court
reasoned that the taxpayer’s omissions were “inadvertent”, and,
thus, analogous to mathematical or posting errors, the correction
of which would not have amounted to a change in method of
accounting. Id.
Taxpayers on other occasions have brought Korn Indus., Inc. to
our attention. See, e.g., Superior Coach of Fla., Inc. v.
Commissioner, 80 T.C. at 912 (facts before us distinguishable from
those in Korn Indus., Inc.); Wayne Bolt & Nut Co. v. Commissioner,
supra at 511 (similar). In Superior Coach, we noted that some
commentators had pointed out that the good-faith exception
seemingly created by Korn Indus., Inc. appears to be without
statutory authorization. Superior Coach, Inc. v. Commissioner,
supra at 914 n.5. Indeed, assuming that consistently made
accounting errors are generally inadvertent (i.e., made in good
faith), an inadvertence-based exception to the general rule (that
the consistent treatment of an item amounts to a method of
accounting) would seem to swallow that general rule. We need not
resolve that conundrum today, because, as in the past, the facts
before us are distinguishable from those in Korn Indus., Inc. v.
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