Hospital Corporation of America and Subsidiaries - Page 31

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          736,14 as did its predecessor and as does it successor,                     
          prescribed general administrative procedures under section 1.446-           
          1(e), Income Tax Regs., for taxpayers to obtain the consent of              
          the Commissioner for changes in methods of accounting for Federal           
          income tax purposes.  The revenue procedure provided, among other           
          things, rules for determining the appropriate period for taking             
          into account the section 481(a) adjustments relating to changes             
          in methods of accounting and under specified circumstances                  
          required acceleration of the reporting of the section 481(a)                
          adjustment, including in the event that a taxpayer ceased to                
          engage in the trade or business to which the section 481(a)                 
          adjustment related, on which occasion the taxpayer had to include           
          any unreported section 481(a) adjustment in income for the year             
          when trade or business ceased.  See Rev. Proc. 84-74, secs. 5.06-           
          5.09, 1984-2 C.B. at 742-744.                                               
               We do not read the cryptic passage in the conference report            
          as a clear expression of congressional intent to restrict the               
          Commissioner's authority to compel acceleration of the 10-year              
          spread of a section 481(a) adjustment relating to a change in               
          method of accounting required under section 448(a) should a                 

          14  Rev. Proc. 84-74, 1984-2 C.B. 736, which clarified,                     
          modified, and superseded Rev. Proc. 80-51, 1980-2 C.B. 818,                 
          effective for Forms 3115, Application for Change in Accounting              
          Method, filed for taxable years beginning on or after Oct. 29,              
          1984, Rev. Proc. 84-74, secs. 1, 11, 1984-2 C.B. at 737, 751, was           
          modified and superseded by Rev. Proc. 92-20, 1992-1 C.B. 685,               
          effective for Forms 3115 filed on or after Mar. 23, 1992, Rev.              
          Proc. 92-20, secs. 1, 14, 1992-1 C.B. at 688, 706.                          




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