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adjustment being reported ratably over a number of years that had
not yet been accounted for at the time a taxpayer ceased to
engage in the trade or business to which the adjustment relates
might be omitted from the income of the trade or business which
gave rise to that section 481(a) adjustment. Thus, in the
absence of a cessation-of-business acceleration provision, a
taxpayer could contravene the general intent of section 481(a),
which is to prevent the omission or duplication of an item of
income or expense as a result of a change in method of
accounting, by merely restructuring its business. Under such
circumstances, the taxpayer would distort its overall lifetime
income.
The rationale for the difference in the spread period for
the section 481(a) adjustment granted hospital and nonhospital
businesses is not explained in either the language of section 448
or its legislative history. It is clear, however, that Congress,
for whatever reason, gave hospitals a longer spread period than
nonhospital businesses in reporting a section 481(a) adjustment
relating to the change in method of accounting required by
section 448(a). Nevertheless, there is nothing in the statute or
its legislative history to indicate that Congress intended to
give hospital businesses an advantage in determining the total
amount of the section 481(a) adjustment that would be required to
be included in income. In other words, in giving hospitals a
longer period within which to account for the section 481(a)
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