Hospital Corporation of America and Subsidiaries - Page 19

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          result of the enactment of section 448(a), and other businesses,            
          which were given a 4-year period that could be shortened under              
          appropriate circumstances.  In support of their position,                   
          petitioners rely on H. Conf. Rept. 99-841 (Vol. 2), at II-288 to            
          II-289 (1986), 1986-3 C.B. (Vol. 4) 1, 288-289, which states in             
          pertinent part as follows:                                                  
               Any adjustment required by section 481 as a result of such             
               change [from the cash method to an accrual method] generally           
               shall be taken into account over a period not to exceed four           
               years.  * * *  In the case of a hospital, the adjustment               
               shall be taken into account ratably over a ten-year period.            
               * * *                                                                  
                    The conferees intend that the timing of the section 481           
               adjustment other than for a hospital will be determined                
               under the provisions of Revenue Procedure 84-74, 1984-2 C.B.           
               736.  * * *                                                            
          We agree with petitioners that Congress intended to provide a               
          different section 481(a) adjustment period for hospitals from the           
          period provided for nonhospital businesses.  We do not agree,               
          however, that the wording of the statute requires the conclusion            
          that under no circumstances may the 10-year spread period for               
          hospitals be shortened.                                                     
               In our view, petitioners have focused their analysis too               
          narrowly in construing section 448(d)(7)(C).  We agree that the             
          phrase "shall be 10 years" by itself appears clear on its face.             
          The language of a statute, however, cannot be viewed in                     
          isolation.  See Norfolk S. Corp. v. Commissioner, 104 T.C. 13,              
          40, supplemented by 104 T.C. 417 (1995).  In construing the                 
          meaning of section 448(d)(7)(C), it is necessary to consider all            




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