Hospital Corporation of America and Subsidiaries - Page 28

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          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 to                




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