Depending on the circumstances, the Judge may or may not grant that request. You should ask the IRS attorney if he or she will agree with the request for continuance and you should let the Tax Court know if there is any objection. The Judge may or may not grant your request for continuance.
If differences exist, then adjustments should be made to get the accounting counts to match the warehouse counts. A full physical inventory is usually performed when all inventory movements are stopped to ensure better accuracy. Cycle counts represent a procedure to validate inventory quantity in the accounting system through regular partial counts.
In perpetual inventory, the system continually estimates the ending inventory. The perpetual system is a records estimating system only, and not a physical check of the inventory. Systems that use perpetual record keeping usually do a periodic physical inventory to verify their records. Perpetual inventory systems cover continuous intake of stock and up-to-date financial records.