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We look to section 6213(g), which lists a number of
different errors that are “mathematical or clerical.” The type
of error that seems most like the one here is “an error in
addition, subtraction, multiplication or division shown on any
return.” Sec. 6213(g)(2)(A). But we cannot agree with Ms.
Goode-Parker that the mistake on her 1996 return was such an
error, because a mistaken failure to add is not the same as “an
error in addition.” As we recently explained in Huffman v.
Commissioner, 126 T.C. 322, 344-345 (2006), there is a
distinction between a “mathematical error” and omitting a step
that requires math. A “mathematical error” occurs when someone
multiplies when he should have divided or when his computation
produces an erroneous result. Id. In this case, Mr. Parker
didn’t botch the addition, he just skipped a step that required
addition, and under Huffman that is not the same thing. See id.
This admittedly very subtle point means that Ms. Goode-Parker’s
liability is neither an understatement nor a deficiency, because
her return showed all the tax imposed.8
That leaves Ms. Goode-Parker able to seek relief only under
section 6015(f). But we held in Billings that we do not have
8 The parties did not argue whether Mr. Parker’s mistake
might be a clerical error under section 6213(g)(2)(C), because it
was “an entry on a return of an item which is inconsistent with
another entry of the same or another item on such return.”
Whether tax computations are “items” is unclear, and we leave any
definitive holding to another day.
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Last modified: May 25, 2011