Hospital Corporation of America and Subsidiaries - Page 62

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               The substantial-identity-of-results test is not applicable             
          under the circumstances present in the instant case.  As we read            
          Asphalt Products, it is clear that the focus of the Court of                
          Appeals for the Sixth Circuit was on the mismatching of the                 
          taxpayer's receipts from the sale of products with its cost of              
          goods sold.  See, e.g., 796 F.2d at 847.  Indeed, that court                
          stated:                                                                     
               If the temporary and rather insignificant increase in                  
               inventories of raw materials had been the only basis                   
               for the Commissioner's determination, we would have                    
               been inclined to find an abuse of discretion.  We do                   
               not construe the Code provisions and regulations                       
               relating to inventories in the absolute terms adopted                  
               by the Commissioner and the Tax Court.  However, the                   
               taxpayer's method of accounting did not produce an                     
               accurate picture of its 1974 income.  The income tax is                
               structured on an annual basis.  Using the cash method,                 
               the cost of materials sold in 1974 was deducted on the                 
               1974 return, yet the proceeds from that portion of the                 
               same sales represented by the accounts receivable were                 
               not included in the taxpayer's gross receipts as                       
               reported on its return.  Unlike the inventory item, the                
               accounts receivable were not negligible before 1974 and                
               did not shrink even to their former size at the end of                 
               the oil emergency.  The taxpayer had accounts                          
               receivable of $238,000 at the end of 1976.  These facts                
               supported the Commissioner's determination that the                    
               cash receipts and disbursements method did not clearly                 
               reflect the taxpayer's income.  [Id. at 849.]                          
               In the instant case, petitioners report patient receivables            
          and related expenses attributable to the Pharmacy and Central               
          Supply accounts on the accrual method.  Consequently, the                   
          presence of the substantial accounts receivable at yearend does             
          not mean "that the cost of goods sold had been deducted while the           







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