Huffman v. Comm'r
United States Tax Court
The sole issue for decision is whether a correction to the inventory method employed by S corporations owned by certain of the petitioners constitutes an accounting method change that requires an adjustment pursuant to sec. 481, I.R.C. For periods ranging from 10 to 20 years, the corporations' accountant, in applying the link-chain, dollar-value method of valuing LIFO inventory, omitted a step required by that method.
Read the full summary
The sole issue for decision is whether a correction to the inventory method employed by S corporations owned by certain of the petitioners constitutes an accounting method change that requires an adjustment pursuant to sec. 481, I.R.C. For periods ranging from 10 to 20 years, the corporations' accountant, in applying the link-chain, dollar-value method of valuing LIFO inventory, omitted a step required by that method. Held: R's revaluations of the corporations' inventories, to correct for the accountant's omissions, constituted changes in a method of accounting employed by the corporations,…
1Opinion of the Court
OPINION
Halpern, Judge:
These cases have been consolidated for purposes of trial, briefing, and opinion. By notices of deficiency dated December 19, 2003 (the notices), respondent determined deficiencies in Federal income taxes as follows:
Taxable (calendar) year deficiency
Petitioners (husband and wife) 1997 1998 1999
Dow A. and Sandra E. Huffman $36,757 $9,413
James A. and Dorothy A. Patterson 35,542
Douglas M. and Kimberlee H. Wolford 33,422 1,966
Neil A. and Ethel M. Huffman $131,408 535,065 304,033
Petitioners have conceded some of the adjustments made by respondent that give rise to the…
2Cases cited19 opinions
- Wayne Bolt & Nut Co. v. CommissionerUnited States Tax Court · 1989
- Fox Chevrolet, Inc. (Maryland) v. CommissionerUnited States Tax Court · 1981
- Standard Oil Co. v. CommissionerUnited States Tax Court · 1981
- Primo Pants Co. v. CommissionerUnited States Tax Court · 1982
- Underhill v. CommissionerUnited States Tax Court · 1966
14 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Huffman v. CommissionerCourt of Appeals for the Sixth Circuit · 2008
- Capital One Fin. Corp. v. Comm'rUnited States Tax Court · 2008
- Capital One Financial Corp. v. CommissionerCourt of Appeals for the Fourth Circuit · 2011
- Bergdale v. Comm'rUnited States Tax Court · 2014
- Transupport, Incorporated v. Commissioner of IRSCourt of Appeals for the First Circuit · 2018
14 more not listed; retrieve them via the Exa API.