- 18 - the transitional rules will apply with the section 481 adjustment amount to be included in income over a period not to exceed ten taxable years, rather than five. * * * [Emphasis supplied.] ___________ 4Under that revenue procedure, the adjustment from a change in accounting generally is included in income over a period equal to the less [sic] of the number of years the taxpayer has used the accounting method or a specified number of years. Petitioners assert that the quoted excerpt is based on language that was not enacted.8 Under the bill as originally proposed, the spread for hospitals was a period that "shall not exceed" 10 years. The law as enacted, however, provides for a spread period that "shall be" 10 years. Petitioners argue that the fact that the provision was changed demonstrates that the difference in treatment for hospital and nonhospital businesses was intentional. Petitioners maintain further that the legislative history relating to section 448(d)(7)(C) confirms that Congress intended to make a distinction between hospitals, which were given a fixed 10-year period to spread section 481(a) adjustments required as a 8 As originally reported by the House Committee on Ways and Means on Dec. 7, 1985, the provision in the bill that subsequently became sec. 448(d)(7)(C) provided as follows: the period for taking into account the adjustment under section 481 by reason of such change [from the cash method to an accrual method of accounting] shall not exceed 5 years (10 years in the case of a hospital described in section 144(b)(3)). [H.R. 3838, 99th Cong., 1st Sess. sec. 902 (1985).]Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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