Hospital Corporation of America and Subsidiaries - Page 61

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          resulted in a mismatching of receipts from sales and cost of                
          sales and therefore the cash method was not appropriate.  The               
          Court of Appeals for the Sixth Circuit agreed that the change of            
          accounting method by the Commissioner was not an abuse of                   
          discretion under the circumstances in that "Though the temporary            
          increase in inventory in the present case was not significant,              
          the large increase in accounts receivable created a situation               
          where only use of the accrual method of accounting would avoid a            
          serious distortion."  Asphalt Prods. Co. v. Commissioner, supra             
          at 848-849.                                                                 
               Relying on Wilkinson-Beane, Inc. v. Commissioner, supra, the           
          Court of Appeals for the Sixth Circuit concluded that "Where the            
          Commissioner has determined that the accounting method used by a            
          taxpayer does not clearly reflect income, in order to prevail,              
          'the taxpayer must demonstrate substantial identity of results              
          between his method and the method selected by the Commissioner.'"           
          Id. at 849.  In that case, the taxpayer reported income from the            
          sale of merchandise on the cash method of accounting.  In the               
          instant case, the hospitals used a hybrid method, not a cash                
          method of accounting.  In Wilkinson-Beane, Inc. v. Commissioner,            
          T.C. Memo. 1969-79, we specifically cautioned that "It must be              
          remembered that our analysis of the above regulations and cases             
          is in the context of the cash or accrual bases of accounting.  We           
          are not faced with a hybrid method."                                        






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