- 35 - section 481(a) adjustment relating to the division's trade or business. Rev. Proc. 87-55, sec. 4.05(1), 1987-2 C.B. 671, 673; see also Rev. Rul. 80-39, 1980-1 C.B. 112 (a corporation seeking permission to change its method of accounting for one of its divisions must agree to include the balance of the related section 481(a) adjustment in income for the year in which the division ceases to engage in that trade or business). In the instant case, petitioners stipulated that each Category B Corporation was a separate enterprise with a separate trade or business and kept separate books and records. The assets of those Category B Corporations consisted of those Facilities owned and operated by the New Parents that HealthTrust wanted to acquire. The Facilities were separate trades or businesses of the New Parents. Indeed, 40 percent of the hospitals were the only hospitals for the communities they served, and 20 percent of the remaining hospitals were one of two hospitals for the communities they served. The New Parents ceased to engage in those trades or businesses when the Facilities were transferred to the Category B Corporations and sold to HealthTrust. Consequently, although the New Parents continued to own and operate other hospitals, office buildings, or medical facilities, they did not continue the business of those Facilities which had been spun off to the Category B Corporations. Requiring the New Parents to include in income the portion of the section 481(a) adjustment attributable to the Category B Corporation for thePage: 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