Hospital Corporation of America and Subsidiaries - Page 20

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          of the words of the statute as well as their context, the                   
          purposes of the law, and the circumstances under which the words            
          were employed.  See Deal v. United States, 508 U.S. 129, 132                
          (1993); Shell Oil Co. v. Iowa Dept. of Revenue, 488 U.S. 19                 
          (1988); Sundstrand Corp. v. Commissioner, 17 F.3d 965, 967 (7th             
          Cir. 1994), affg. 98 T.C. 518 (1992).  Furthermore, we must view            
          the statute in context as a whole and with a view to its place in           
          the overall statutory scheme.  King v. St. Vincent's Hosp., 502             
          U.S. 215, 221 (1991); Stanford v. Commissioner, 297 F.2d 298, 308           
          (9th Cir. 1961), affg. 34 T.C. 1150 (1960); Norfolk S. Corp. v.             
          Commissioner, supra at 41.                                                  
               Section 448(d)(7)(C)(ii) provides that, for purposes of                
          determining the period for taking into account a section 481(a)             
          adjustment relating to a change in method of accounting required            
          under section 448(a), the spread period "in the case of a                   
          hospital, shall be 10 years."  Petitioners' analysis of the                 
          statutory language focuses primarily on the phrase "shall be 10             
          years."  Their analysis basically ignores the other words in the            
          statute and the purposes of the statutory provision as a whole.             
               On brief, neither party addresses the significance of                  
          Congress' choice of the term "a hospital" in section                        
          448(d)(7)(C)(ii) to the precise question involved in the instant            
          opinion.  Indeed, petitioners generally paraphrase section                  
          448(d)(7)(C)(ii) to read:  "the period for taking into account              
          the adjustment under section 481 for hospitals shall be 10                  




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