- 52 - 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.Page: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 Next
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