Hospital Corporation of America and Subsidiaries - Page 6

                                        - 6 -                                         

          certain items relating to hospital facilities constructed during            
          those taxable years, and claimed the investment tax credit                  
          (ITC),3 and depreciation deductions using a 5-year recovery                 
          period.  Respondent, however, determined in the notice of                   
          deficiency that a number of those items were structural                     
          components of the related buildings and not personal property,              
          that those items were not eligible for ITC, and that they must be           
          depreciated over the same recovery period as the buildings to               
          which they related.  Prior to trial, the parties resolved the ITC           
          issue, leaving for trial the issue of the proper classification             
          of the property items for purposes of claiming the depreciation             
          deduction for the taxable years in issue.                                   
               On their tax returns for taxable years ended 1987 and 1988,            
          petitioners classified as tangible personal property certain                
          items relating to hospital facilities constructed during those              
          years and claimed depreciation deductions using a 5-year recovery           
          period.  Respondent, however, determined in the notice of                   
          deficiency that a number of those items were structural                     
          components of the related buildings and that they must be                   
          depreciated over the same recovery period as the buildings to               
          which they related.                                                         



          3   The investment tax credit (ITC) was repealed by the Tax                 
          Reform Act of 1986, Pub. L. 99-514, sec. 211(a), 100 Stat. 2166,            
          effective (subject to transition rules) for property placed in              
          service after Dec. 31, 1985.                                                



Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011