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T. Henderson, Jr., and John W. Bonds, Jr., for petitioners in
docket No. 28588-91.
N. Jerold Cohen, Reginald J. Clark, Randolph W. Thrower,
Walter T. Henderson, Jr., and John W. Bonds, Jr., for petitioners
in docket No. 6351-92.
Robert J. Shilliday, Jr., Vallie C. Brooks, and William B.
McCarthy, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge: These cases were consolidated for purposes of
trial, briefing, and opinion and will hereinafter be referred to
as the instant case.1 Respondent determined deficiencies in
petitioners' consolidated corporate Federal income tax as shown
below.
1 The instant case involves several issues, some of which have
been settled or decided. The issues remaining for decision
involve matters falling into three reasonably distinct
categories, which the parties have denominated the HealthTrust
issue, the MACRS depreciation issue, and the captive insurance or
Parthenon Insurance Co. issues. Issues involved in the first two
categories were presented at a special trial session together
with certain tax accounting issues previously decided, and the
captive insurance issues were severed for trial purposes and were
presented at a subsequent special trial session. Separate briefs
of the parties were filed for each of the distinct categories of
issues. We addressed the tax accounting issues in Hospital Corp.
of Am. v. Commissioner, T.C. Memo. 1996-105; Hospital Corp. of
Am. v. Commissioner, 107 T.C. 73 (1996); and Hospital Corp. of
Am. v. Commissioner, 107 T.C. 116 (1996). The instant opinion
addresses the HealthTrust issue. Other issues will be addressed
in one or more separate opinions subsequently to be released.
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