- 53 - Respondent’s acquiescence in petitioners’ use of the hybrid method and the hybrid method as modified or as further modified over four consecutive audit cycles to compute taxable income of the applicable hospitals, while not binding on respondent, under the circumstances of the instant case is a factor in petitioners’ favor. See Klein Chocolate Co. v. Commissioner, 36 T.C. 142 (1961); Geometric Stamping Co. v. Commissioner, 26 T.C. 301 (1956); see also Public Service Co. v. Commissioner, 78 T.C. 445, 456 (1982). Another favorable factor is the overwhelming acceptance of the cash method of accounting in the health care industry. See Public Service Co. v. Commissioner, supra; Madison Gas & Electric Co. v. Commissioner, 72 T.C. 521, 556 (1979), affd. 633 F.2d 512 (7th Cir. 1980). Additionally, petitioners’ hospitals are in the health care industry, which is primarily a service industry. See St. Luke’s Hospital, Inc. v. Commissioner, 35 T.C. 236, 238 (1960); see also “Audits of Providers of Health Care Services”, AICPA Audit and Accounting Guide (1992); Office of Management and Budget, Standard Industrial Classification Manual, 387-388 (1987). Such industries historically have been permitted to use the cash method. Respondent objects to petitioners' use of the hybrid method of accounting for the hospitals because of the disparity between the income reported under that method and the income that would have been reported had the hospitals employed an overall accrualPage: Previous 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 Next
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