Dow A. and Sandra E. Huffman, et al. - Page 52

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          1.446-1(e)(2)(ii)(b), Income Tax Regs., either a mathematical or            
          posting error.20  While, in some circumstances, a taxpayer deviating        
          from its previously established method of accounting may again              
          adhere to its established method before the deviation has time to           
          harden into a method of its own, the accountant’s consistent error          
          for no less than 10 years rules out that possibility.  The                  
          accountant’s method was, therefore, a material item in each                 
          member’s overall plan of accounting.  Respondent’s change to the            
          accountant’s method (a material item) was, thus, a change in method         
          of accounting.                                                              
          IV.  Conclusion                                                             
               For the first year in issue of each member, respondent’s               
          revaluation of the member’s inventory constituted a change in the           
          member’s method of accounting.  Therefore, respondent’s section             
          481(a) adjustments are permissible.  Each petitioner owning shares          
          of stock in any member of the Huffman group must take into account          
          his or her share of the section 481 adjustments.  We need decide no         
          other issue.                                                                

               20  It is worth mentioning that the use of price indexes in            
          applying the dollar-value method is a matter to which Congress in           
          sec. 472(f) and the Secretary of the Treasury in his regulations,           
          see, e.g., sec. 1.472-8(e)(3), and revenue procedures have                  
          devoted attention.  Among the latter are Rev. Proc. 97-36, 1997-2           
          C.B. 450, and Rev. Proc. 97-37, 1997-2 C.B. 455  The first of               
          those revenue procedures describes the adoption of the                      
          “Alternative LIFO Method” (a dollar-value link-chain method for             
          retailers of autos and light-duty trucks) as a change in method             
          of accounting.  The second likewise describes the  inventory                
          price index computation (IPIC) method.                                      




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