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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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