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HUFFMAN v. C.I.R.

Nos. 06-2134, 06-2135, 06-2136, 07-1180.

518 F.3d 357 (2008)

Dow A. HUFFMAN (06-2134/2135) and Kimberlee H. Wolford (06-2135/2136), Individually and as Personal Representatives of the Estate of Neil A. Huffman; Sandra E. Huffman (06-2134); Ethel M. Huffman (06-2135); Douglas M. Wolford (06-2136); James A. Patterson (07-1180); Dorothy A. Patterson (07-1180), Petitioners-Appellants, v. COMMISSIONER of INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: March 4, 2008.

Attorney(s) appearing for the Case

ARGUED: Mark F. Sommer, Greenebaum, Doll & McDonald, Louisville, Kentucky, for Appellant. Michelle B. Smalling, United States Department of Justice, Washington, D.C., for Appellee. ON BRIEF: Mark F. Sommer, Greenebaum, Doll & McDonald, Louisville, Kentucky, for Appellant. Michelle B. Smalling, Jonathan S. Cohen, United States Department of Justice, Washington, D.C., for Appellee.

Before: SUHRHEINRICH and ROGERS, Circuit Judges; BELL, Chief District Judge.

OPINION

ROGERS, Circuit Judge.

The Tax Court upheld the determination by the Commissioner of Internal Revenue that the correction of a consistently repeated inventory accounting error in this case amounted to a "change in method of accounting" under I.R.C. § 481. Section 481 permits correction of accounts for otherwise time-barred years. Because the Commissioner properly determined that § 481 applies, we affirm.

Taxpayers are shareholders...

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