- 57 - 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.Page: Previous 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 Next
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