Hospital Corporation of America and Subsidiaries - Page 43

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          Commissioner, 97 T.C. 120, 128 (1991); UFE, Inc. v. Commissioner,           
          92 T.C. 1314, 1321 (1989); Sandor v. Commissioner, 62 T.C. 469,             
          477 (1974), affd. 536 F.2d 874 (9th Cir. 1976).  Moreover, an               
          accounting method that conforms to GAAP, but does not comply with           
          the Commissioner's regulations, may not clearly reflect income.             
          Peninsula Steel Prods. & Equip. Co. v. Commissioner, supra.                 
               Section 446(c) specifically recognizes as permissible                  
          methods of accounting, the cash receipts and disbursements method           
          (cash method), an accrual method, any other method permitted by             
          chapter 1 of the Internal Revenue Code, or any combination of the           
          foregoing methods permitted under regulations prescribed by the             
          Secretary of the Treasury (a hybrid method).  Generally, under              
          the cash method of accounting, an item of income or expense is              
          reported when received or paid, without regard to the economic              
          events giving rise to the item.  Under an accrual method of                 
          accounting, on the other hand, an item of income or expense                 
          generally is reported for the accounting period during which all            
          the events have occurred which fix the taxpayer's right to                  
          receive the item of income or which establish the fact of                   
          liability giving rise to the deduction, and the amount thereof              
          can be determined with reasonable accuracy.18  Hallmark Cards,              



          18                                                                          
               For years after 1984, sec. 461(h) also requires the                    
          occurrence of economic performance with respect to a liability.             




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