Hospital Corporation of America and Subsidiaries - Page 32

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          taxpayer cease to engage in the trade or business to which that             
          adjustment relates.  As we discussed above, we find the                     
          cessation-of-business acceleration provision a permissible                  
          construction of the statute inasmuch as it fulfills the                     
          congressional objective of coordinating section 448(a) and                  
          section 481(a) in a reasonable manner.  In our view, the presence           
          of a similar provision in Rev. Proc. 84-74 is not sufficient to             
          defeat its inclusion in the regulations.                                    
               The rules and requirements of Rev. Proc. 84-74 were detailed           
          and complex.  The language of section 448(d)(7)(C) and of its               
          legislative history gives no indication that Congress even                  
          focused on the cessation-of-business acceleration provision                 
          contained in that revenue procedure.  Moreover, the requirement             
          that the balance of a section 481(a) adjustment must be taken               
          into income when a taxpayer ceases to engage in the trade or                
          business to which the section 481(a) adjustment relates is not a            
          condition unique to Rev. Proc. 84-74.  Indeed, commencing at                
          least from the early 1970's, a cessation-of-business acceleration           
          provision appears to have been included customarily as a                    
          condition to consent to a spread of a section 481(a) adjustment             
          whenever the Commissioner issued a change in accounting method              
          ruling.  See, e.g., Rev. Rul. 85-134, 1985-2 C.B. 160; Rev. Rul.            
          80-39, 1980-1 C.B. 112; Rev. Rul. 77-264, 1977-2 C.B. 187; Rev.             
          Rul. 70-318, 1970-1 C.B. 113; see also Rev. Proc. 85-8, 1985-1              
          C.B. 495 (procedure for accrual basis taxpayers to change method            




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