Hospital Corporation of America and Subsidiaries - Page 6

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          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.                                                    




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