- 27 - 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)Page: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
Last modified: May 25, 2011