Hospital Corporation of America and Subsidiaries - Page 23

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          10  (...continued)                                                          
                    taxpayer used the cash method, or                                 
                         (B) 4 taxable years, provided the                            
                    taxpayer complies with the provisions of                          
                    paragraph (h)(2) or (h)(3) of this section                        
                    for its first section 448 year.                                   
                    (ii) Hospital timing rules--(A) In general.  In the               
               case of a hospital that is required by this section to                 
               change from the cash method, the section 481(a) adjustment             
               shall be taken into account ratably (beginning with the year           
               of change) over 10 years, provided the taxpayer complies               
               with the provisions of paragraph (h)(2) or (h)(3) of this              
               section for its first section 448 year.                                
                    *       *       *       *       *       *       *                 
                    (iii) Untimely change in method of accounting to comply           
               with this section.  Unless a taxpayer (including a hospital            
               and a cooperative) required by this section to change from             
               the cash method complies with the provisions of paragraph              
               (h)(2) or (h)(3) of this section for its first section 448             
               year within the time prescribed by those paragraphs, the               
               taxpayer must take the section 481(a) adjustment into                  
               account under the provisions of any applicable                         
               administrative procedure that is prescribed by the                     
               Commissioner after January 7, 1991, specifically for                   
               purposes of complying with this section.  Absent such an               
               administrative procedure, a taxpayer must request a change             
               under �1.446-1(e)(3) and shall be subject to any terms and             
               conditions (including the year of change) as may be imposed            
               by the Commissioner.                                                   
                    (3) Special timing rules for section 481(a) adjustment--          
               (i) One-third rule.  If, during the period the section 481(a)          
               adjustment is to be taken into account, the balance of the             
               taxpayer's accounts receivable as of the last day of each of           
               two consecutive taxable years is less than 66 2/3 percent of           
               the taxpayer's accounts receivable balance at the beginning            
               of the first year of the section 481(a) adjustment, the                
               balance of the section 481(a) adjustment (relating to                  
               accounts receivable) not previously taken into account shall           
               be included in income in the second taxable year.  This                
               paragraph (g)(3)(i) shall not apply to any hospital * * *              
                                                             (continued...)           




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