Hospital Corporation of America and Subsidiaries - Page 24

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          regulations, effective generally for taxable years beginning                
          after December 31, 1986, were promulgated in 1993 pursuant to the           
          Commissioner's authority found in section 7805(a) to "prescribe             
          all needful rules and regulations for the enforcement of this               
          title".  T.D. 8514, 1994-1 C.B. 141; sec. 1.448-1(i)(1), Income             
          Tax Regs.11  The final regulations interpreting section                     

          10  (...continued)                                                          
                    *       *       *       *       *       *       *                 
                    (iii) Cessation of trade or business.  If the taxpayer            
               ceases to engage in the trade or business to which the                 
               section 481(a) adjustment relates, or if the taxpayer                  
               operating the trade or business terminates existence, and              
               such cessation or termination occurs prior to the expiration           
               of the adjustment period described in paragraph (g)(2)(i) or           
               (ii) of this section, the taxpayer must take into account, in          
               the taxable year of such cessation or termination, the                 
               balance of the adjustment not previously taken into account            
               in computing taxable income.  For purposes of this paragraph           
               (g)(3)(iii), the determination as to whether a taxpayer has            
               ceased to engage in the trade or business to which the                 
               section 481(a) adjustment relates, or has terminated its               
               existence, is to be made under the principles of �1.446-               
               1(e)(3)(ii) and its underlying administrative procedures.              


          11  Sec. 1.448-1(i), Income Tax Regs., provides in pertinent                
          part as follows:                                                            
                    (i) Effective date.  (1) In general.  Except as                   
               provided in paragraph (i)(2), (3), and (4) of this section,            
               this section applies to any taxable year beginning after               
               December 31, 1986.                                                     
                    *       *       *       *       *       *       *                 
                    (4) Transitional rule for paragraphs (g) and (h)                  
               of this section.  To the extent the provisions of                      
               paragraphs (g) and (h) of this section were not                        
               reflected in paragraphs (g) and (h) of �1.448-1T (as                   
                                                             (continued...)           




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