United States Sixth Circuit

In a tax case arising after notices of federal income tax deficiencies were issued to shareholders of various new and used car dealerships, a rejection of taxpayers' challenge to the determination of the deficiencies is affirmed where the Commissioner properly determined 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. section 481, which permits correction of accounts for otherwise time-barred years.

Appellate Information

• Decided 03/04/2008
• Published 03/04/2008

Judges

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

Court

• United States Sixth Circuit

Counsel

• For Appellees:
  
• 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.