- 28 - available to respondent's agents examining petitioners' books and returns. 1972-73 Audit At the end of 1973, petitioners owned and operated 45 hospitals. During an examination of petitioners' corporate income tax returns for the taxable years ended 1972 and 1973, the Internal Revenue Service (IRS) District Director, Nashville, Tennessee, proposed a number of adjustments, including a proposal to change the method of accounting of HCA's hospitals using the cash method to an accrual method. As grounds for the proposal to place those hospitals on an accrual method of accounting, the revenue agent's report (RAR) asserted, inter alia, that, because inventories were material and had a direct effect on taxable income, the cash method did not properly reflect income. The RAR also asserted that the cash method did not properly reflect petitioners' income, regardless of inventories, because the cash method did not match revenue with expenditures. Furthermore, the RAR indicated that petitioners had not obtained the approval of the Commissioner of Internal Revenue (Commissioner) to change the method of accounting from the accrual basis used to maintain their books and records to the cash method used for tax purposes. Additionally, the RAR stated that, because the purchase or sale of merchandise was an income-producing factor for petitioners' hospitals, they were required to use inventories pursuant toPage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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