- 6 - prior to January 1, 1987, changed their method of accounting to that method. Commencing with taxable year ended 1987 those petitioners took into account positive section 481(a) adjustments4 necessary to effect the change to an overall accrual method over the periods provided by section 448(d)(7)(C).5 Thus, on the consolidated return for taxable year ended 1987, those petitioners operating hospitals not theretofore reporting on an 4 Sec. 481(a) provides generally that, if a taxpayer's method of accounting is changed from the method used for the preceding taxable year, adjustments determined necessary solely by reason of the change to prevent amounts from being duplicated or omitted are to be taken into account for the year of change to compute taxable income. A positive sec. 481(a) adjustment increases taxable income, and a negative sec. 481(a) adjustment decreases taxable income. Sec. 481(c) additionally provides generally that the sec. 481(a) adjustment may be taken into account over the period and pursuant to the terms and conditions permitted by regulations. See also sec. 1.481-5, Income Tax Regs., now incorporated in sec. 1.481-4, Income Tax Regs. 5 Sec. 448(d)(7) provides as follows: (7) Coordination with section 481.--In the case of any taxpayer required by this section to change its method of accounting for any taxable year-- (A) such change shall be treated as initiated by the taxpayer, (B) such change shall be treated as made with the consent of the Secretary, and (C) the period for taking into account the adjustments under section 481 by reason of such change-- (i) except as provided in clause (ii), shall not exceed 4 years, and (ii) in the case of a hospital, shall be 10 years.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011