Legal Opinion

Huffman v. Comm'r

United States Tax Court

Decided May 16, 2006No. Nos. 2845-04, 2846-04, 2847-04, 2848-04PublishedCited by 19 opinions

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.

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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

  1. Wayne Bolt & Nut Co. v. CommissionerUnited States Tax Court · 1989
  2. Fox Chevrolet, Inc. (Maryland) v. CommissionerUnited States Tax Court · 1981
  3. Standard Oil Co. v. CommissionerUnited States Tax Court · 1981
  4. Primo Pants Co. v. CommissionerUnited States Tax Court · 1982
  5. Underhill v. CommissionerUnited States Tax Court · 1966

14 more not listed; retrieve them via the Exa API.

3Cited by19 opinions

  1. Huffman v. CommissionerCourt of Appeals for the Sixth Circuit · 2008
  2. Capital One Fin. Corp. v. Comm'rUnited States Tax Court · 2008
  3. Capital One Financial Corp. v. CommissionerCourt of Appeals for the Fourth Circuit · 2011
  4. Bergdale v. Comm'rUnited States Tax Court · 2014
  5. Transupport, Incorporated v. Commissioner of IRSCourt of Appeals for the First Circuit · 2018

14 more not listed; retrieve them via the Exa API.

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