Hospital Corporation of America and Subsidiaries - Page 7

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          Petitioners elected to use the periodic system6 of the                      
          nonaccrual-experience method to estimate on a hospital-by-                  
          hospital basis the portion of their income they would not collect           
          (sometimes hereinafter referred to as the Uncollectible Amount),            
          except that petitioners computed the Uncollectible Amount by                
          using the formula (Original Formula)7 set forth in section 1.448-           
          2T(e)(2)(i), Temporary Income Tax Regs., 52 Fed. Reg. 22775 (June           
          16, 1987) (Original Temporary Regulations), rather than the                 
          formula (Amended Formula) set forth in amended section 1.448-               
          2T(e)(2), Temporary Income Tax Regs., 53 Fed. Reg. 12513-12514              
          (Apr. 15, 1988) (Amended Temporary Regulations).  Hereinafter, we           
          sometimes will refer to the method petitioners used to compute              
          the Uncollectible Amount for years ended 1987 and 1988 as the               
          modified periodic system.                                                   
               For taxable years ended 1987 and 1988, petitioners reduced             
          (or increased) income of each hospital by the sum of (1) net                


          5  (...continued)                                                           
          collect.  Sec. 448(d)(5).  See infra pp. 17-21 for a detailed               
          description of the nonaccrual-experience method.  Pursuant to               
          sec. 1.448-2T(h)(1), Temporary Income Tax Regs., 52 Fed. Reg.               
          22776 (June 16, 1987), consent to a change to the nonaccrual-               
          experience method is granted automatically if the taxpayer is               
          qualified to use that method.                                               
          6  The periodic system of the nonaccrual-experience method,                 
          described in Notice 88-51, 1988-1 C.B. 535, is similar to a                 
          reserve system.  See infra pp. 20-21 for a detailed description             
          of the periodic system.                                                     
          7  The parties agree that the Original Formula is identical to              
          the Black Motor formula.                                                    




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