Hospital Corporation of America and Subsidiaries - Page 27

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          adjustment being reported ratably over a number of years that had           
          not yet been accounted for at the time a taxpayer ceased to                 
          engage in the trade or business to which the adjustment relates             
          might be omitted from the income of the trade or business which             
          gave rise to that section 481(a) adjustment.  Thus, in the                  
          absence of a cessation-of-business acceleration provision, a                
          taxpayer could contravene the general intent of section 481(a),             
          which is to prevent the omission or duplication of an item of               
          income or expense as a result of a change in method of                      
          accounting, by merely restructuring its business.  Under such               
          circumstances, the taxpayer would distort its overall lifetime              
          income.                                                                     
               The rationale for the difference in the spread period for              
          the section 481(a) adjustment granted hospital and nonhospital              
          businesses is not explained in either the language of section 448           
          or its legislative history.  It is clear, however, that Congress,           
          for whatever reason, gave hospitals a longer spread period than             
          nonhospital businesses in reporting a section 481(a) adjustment             
          relating to the change in method of accounting required by                  
          section 448(a).  Nevertheless, there is nothing in the statute or           
          its legislative history to indicate that Congress intended to               
          give hospital businesses an advantage in determining the total              
          amount of the section 481(a) adjustment that would be required to           
          be included in income.  In other words, in giving hospitals a               
          longer period within which to account for the section 481(a)                




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