Hospital Corporation of America and Subsidiaries - Page 17

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               Section 448(d)(7)(C)(i) generally provides that a taxpayer             
          required by section 448(a) to change from the cash method of                
          accounting may spread the section 481(a) adjustment attributable            
          to that change over a period that "shall not exceed 4 years".               
          Section 448(d)(7)(C)(ii), however, provides that, for "a                    
          hospital", the spread period "shall be 10 years."  See supra note           
          5.                                                                          
               Respondent argues that the phrase "shall not exceed", which            
          modifies the 4-year spread period provided in clause (i) of                 
          section 448(d)(7)(C), applies also to the 10-year spread period             
          specified for hospitals in clause (ii) of that section.                     
          Respondent relies on the following excerpt from H. Rept. 99-426,            
          at 608-609 (1985), 1986-3 C.B. (Vol. 2) 1, 608-609, to support              
          the position that Congress did not intend to give hospitals,                
          under all circumstances, an unlimited 10-year period for the                
          section 481(a) adjustment:                                                  
               Transitional rules                                                     
                    The committee bill treats any change from the cash                
               method of accounting required as a result of the committee             
               bill as a change in the taxpayer's method of accounting,               
               initiated by the taxpayer with the consent of the Secretary            
               of the Treasury.  In order to prevent items of income and              
               expense from being included in taxable income either twice             
               or not at all, an adjustment under section 481 is required             
               to be made.  The amount of such adjustment will be included            
               in income over a period not to exceed five taxable years.              
               It is expected that the concepts of Revenue Procedure 84-74,           
               1984-2 C.B. 736, generally will apply to determine the                 
               actual timing of recognition of income or expense as a                 
               result of the adjustment.4                                             
                    In the case of the business of operating a hospital,              




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