- 47 -
adherence do not amount to changes in any accounting method.
Respondent distinguishes those cases by arguing that, though the
members duly elected the link-chain method, because the method was
never properly applied, the Huffman Group never adopted the link-
chain method.
We agree with respondent that the facts of Gimbel Bros., Inc.
and Standard Oil Co. are distinguishable from those now before us.
The parties have stipulated that, for each member, for the election
and following years (i.e., for 10 or 20 years), the accountant
omitted a computational step required by the regulations governing
the dollar-value method of pricing LIFO inventories. We agree with
respondent that the members may, individually, have elected the
link-chain method, but no member adopted it until respondent made
his corrections. That alone distinguishes the facts before us from
those in Gimbel Bros., Inc. and Standard Oil, Co., where the errors
were committed in the context of a broader compliance with the
taxpayer’s proper method of accounting. Moreover, although
stipulated by the parties, it is questionable whether all four of
the members actually elected to use the link-chain method to value
their respective inventories.18 Gimbel Bros., Inc. and Standard Oil
Co. are distinguished.
4. Discussion
There is an evident incongruity between section 1.446-
18 See supra note 10.
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