Hospital Corporation of America and Subsidiaries - Page 40

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          however, specifies that "the Secretary of the Treasury may                  
          provide a periodic system of accounting for billings that, on the           
          basis of experience, will not be collected where the periodic               
          system results in the same taxable income as would be the case              
          were each receivable recorded separately."  In Notice 88-51,                
          1988-1 C.B. 535, the Commissioner published the periodic system             
          as an alternative to the separate receivable system under section           
          1.448-2T(e)(3), Temporary Income Tax Regs., 53 Fed. Reg. 12513-             
          12514 (Apr. 15, 1988).                                                      
               Petitioners assert that the periodic system provided by the            
          Commissioner uses an inappropriate formula to estimate the                  
          portion of yearend accounts receivable that a taxpayer will not             
          collect.  Petitioners argue that, to prevent an incorrect result,           
          a formula applied to yearend accounts receivable balances must be           
          based on the relationship of writeoffs to yearend accounts                  
          receivable balances, not the relationship of writeoffs to annual            
          charges.  Accordingly, petitioners' challenge to the periodic               
          system is premised on their contention that the Amended Formula,            
          on which the periodic system is based, is invalid.  We already              
          have concluded that the Amended Formula is a permissible                    
          construction of section 448(d)(5).  Accordingly, we conclude that           
          the periodic system of the nonaccrual-experience method is                  
          reasonable and, therefore, valid.                                           








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