Hospital Corporation of America and Subsidiaries - Page 57

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               reflects income, we will not sustain respondent's                      
               determination merely because it produces more income                   
               tax for the taxable year under consideration.  * * *                   
               Disparity in amount is not, per se, necessarily                        
               indicative of a failure to clearly reflect income.                     
               * * * [Id.; fn. ref. omitted.]                                         
               In the instant case, the record as a whole suggests that a             
          substantial portion of the disparity between income reported on             
          the accrual method and income reported on the hybrid method                 
          results from respondent's proposed accrual of revenue related to            
          room charges and ancillary services.  Such ancillary services               
          would include the use of special facilities such as the operating           
          room, the recovery room, and the delivery room, as well as                  
          laboratory tests, x-rays, physical therapy, and group and                   
          individual therapy for psychiatric patients.  Because such income           
          results from the provision of services, it historically has been            
          reported on the cash method.                                                
               We also are persuaded by the statement of Mr. Duis, one of             
          petitioners’ experts, that the increase in accounts receivable              
          reflected on petitioners' returns for the years in issue                    
          primarily resulted from the rapid increase in the number of                 
          hospitals that formed HCA over those years and not from a change            
          in business practice.  Consequently, we do not find that the                
          disparity in income reported under the hybrid method from that              
          which would have been reported under an accrual method sufficient           
          reason in the instant case for requiring the hospitals to adopt             
          an overall accrual method of accounting.                                    





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