Hospital Corporation of America and Subsidiaries - Page 35

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          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 the               




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