- 19 - 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 allPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011