Hospital Corporation of America & Subsidiaries v. Commissioner of Internal Revenue

OPINION

BOYCE F. MARTIN, JR., Circuit Judge.

The petitioner, Hospital Corporation of America and subsidiaries, appeals from two decisions of the United States Tax Court ruling in favor of the Commissioner of the Internal Revenue. First, the Tax Court found that the Secretary of the Treasury reasonably interpreted Internal Revenue Code Section 448(d)(5) in promulgating a mandatory formula to calculate expected uncollectible receivables. Second, the Tax Court ruled that Hospital Corporation must report in a single taxable year the entire remaining balance of an adjustment resulting from a change…