Hospital Corporation of America and Subsidiaries - Page 21

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          receivable outstanding at that time.  Income is increased to                
          reflect any decrease in the reserve balance or decreased to                 
          reflect any increase in that balance.  Notice 88-51, 1988-1 C.B.            
          at 536.  Accordingly, the periodic system of the nonaccrual-                
          experience method of accounting is somewhat similar to a reserve            
          method.  Id.                                                                
               The periodic system requires the taxpayer to charge wholly             
          or partially worthless accounts receivable directly to bad debt             
          expense, ignoring the Uncollectible Amounts pertaining to those             
          accounts receivable.  Similarly, the taxpayer must disregard the            
          Uncollectible Amounts of accounts receivable when it accounts for           
          the collection of those receivables.  Id.  The 6-year moving                
          average formula is used to estimate the total amount of all                 
          eligible accounts receivable outstanding at yearend that the                
          taxpayer estimates it will not collect, including accounts                  
          receivable outstanding at the end of prior taxable years.  Id.              
               Is Section 448(d)(5) Ambiguous?                                        
               Petitioners contend that the Amended Regulations are invalid           
          because they are an unreasonable interpretation of an unambiguous           
          statutory provision.  In response, respondent contends that the             
          statute is ambiguous in that it does not specify how "experience"           
          is to be determined.  Respondent contends further that the                  
          Amended Regulations are a valid interpretation of the statute.              
               In construing section 448(d)(5) our task is to give effect             
          to the intent of Congress.  We begin with the statutory language,           




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