Hospital Corporation of America and Subsidiaries - Page 38

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          in two different ways.  Although the Black Motor formula is a               
          conceivable method for calculating the Uncollectible Amount, and            
          perhaps even a better choice, it is not the only possible method,           
          and it is not even one of the two versions of the formula that is           
          described in H. Rept. 99-426, supra at 608, 1986-3 C.B. (Vol. 2)            
          at 608.  Under the circumstances, we must defer to the                      
          Secretary's choice of formula if the method he selected is                  
          reasonable.  Chevron U.S.A., Inc. v. Natural Res. Def. Council,             
          Inc., 467 U.S. at 843; Peoples Fed. Sav. & Loan Association v.              
          Commissioner, 948 F.2d at 299-300; see also National Muffler                
          Dealers Association v. United States, 440 U.S. at 488; United               
          States v. Correll, 389 U.S. at 306-307.                                     
               Petitioners further argue essentially that the Amended                 
          Formula cannot be valid because the formula does not equal the              
          hospitals' actual bad debt writeoff experience.  We do not                  
          believe that section 448(d)(5) requires an exact matching of the            
          Uncollectible Amount with a taxpayer's actual bad debt writeoff             
          experience.  A statistical approximation of the Uncollectible               
          Amount determined under the prescribed formula appears to be all            
          that was contemplated by Congress.  See H. Rept. 99-426, supra at           
          608, 1986-3 C.B. (Vol. 2) at 608, H. Conf. Rept. 99-841 (Vol. 2),           
          at II-288 (1986), 1986-3 C.B. (Vol. 4) 1, 288.  As to the                   
          nonaccrual-experience method, the conference report states the              
          following:                                                                  






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