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accounting required by section 448(a) that are attributable to
the Facilities because section 448(d)(7)(C)(ii) clearly and
unambiguously gives hospitals a 10-year period in which to spread
any section 481(a) adjustment relating to a change in accounting
method required by section 448(a). As a result, petitioners
argue, resort to the legislative history of section 448 is not
appropriate. Petitioners contend further that the legislative
history of section 448(d)(7) supports the plain meaning of the
statute.
Respondent contends, on the other hand, that, upon
disposition of the hospital to which the adjustment relates, the
spread period that section 448(d)(7)(C)(ii) provides for
hospitals to account for section 481(a) adjustments relating to a
change in accounting method required under section 448(a) may be
less than 10 years. Respondent maintains that the legislative
history of section 448(d)(7) supports the position that the
spread period for hospitals is not to remain 10 years under such
circumstances.
In construing section 448(d)(7) our task is to give effect
to the intent of Congress. We begin with the statutory language,
which is the most persuasive evidence of the statutory purpose.
United States v. American Trucking Associations, Inc., 310 U.S.
534, 542-543 (1940); Helvering v. Stockholms Enskilda Bank, 293
U.S. 84, 93-94 (1934); General Signal Corp. & Subs. v.
Commissioner, 103 T.C. 216, 240 (1994), supplemented by 104 T.C.
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