107 T.C. No. 6 UNITED STATES TAX COURT HOSPITAL CORPORATION OF AMERICA AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 10663-91, 13074-91 Filed September 12, 1996. 28588-91, 6351-92. Ps own, operate, and manage hospitals and related businesses. For taxable year ended 1987, pursuant to sec. 448, I.R.C., Ps not already using an overall accrual method changed their method of accounting to that method. Also during 1987, HCAII, a wholly owned subsidiary of HCA, sold all of the stock of some subsidiaries that owned and operated hospitals and other facilities. On audit, R determined that for certain of those subsidiaries (Category B Corporations) Ps had to include in income for taxable year ended 1987 the entire sec. 481, I.R.C., adjustment relating to the change in method of accounting required by sec. 448, I.R.C. Ps contend that, even though the Category B Corporations were sold during 1987, pursuant to sec. 448(d)(7)(C)(ii), I.R.C., HCA is entitled to include ratably in income over a 10-year period the portion of the sec. 481(a), I.R.C., adjustment attributable to thePage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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