Hospital Corporation of America and Subsidiaries - Page 34

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          to prescribe the cessation-of-business acceleration provision as            
          a condition to obtaining consent to a change in method of                   
          accounting and a spread of the resulting section 481(a)                     
          adjustment).  Accordingly, we conclude that the presence of a               
          cessation-of-business acceleration provision in Rev. Proc. 84-74            
          does not render section 1.448-1(g)(3)(iii), Income Tax Regs.,               
          inconsistent with section 448(d)(7)(C).                                     
               Additionally, we conclude that requiring the Category B                
          Corporations to include the entire balance of the section 481(a)            
          adjustment in income for 1987 is within the scope of section                
          1.448-1(g)(3)(iii), Income Tax Regs.  The cessation-of-business             
          acceleration provision contained in the regulations is applicable           
          whenever a "taxpayer has ceased to engage in the trade or                   
          business to which the section 481(a) adjustment relates" prior to           
          the end of the adjustment period.  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 made under the principles of section 1.446-               
          1(e)(3)(ii), Income Tax Regs., and its underlying administrative            
          procedures.  Sec. 1.448-1(g)(3)(iii), Income Tax Regs.                      
               Respondent has taken the position that where a corporation             
          maintains different divisions for each trade or business and one            
          of the divisions ceases to engage in its trade or business, the             
          corporation ceases to engage in that trade or business and,                 
          therefore, must include in income any remaining portion of a                




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