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Tax Year Ended Deficiency
1978 $2,187,079.00
1980 388,006.58
1981 94,605,958.92
1982 29,691,505.11
1983 43,738,703.50
1984 53,831,713.90
1985 85,613,533.00
1986 69,331,412.00
1987 294,571,908.00
1988 25,317,840.00
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
The issue to be decided in the instant opinion is the amount
petitioners realized during tax years ended 1987 and 1988 from
the sale of the stock of certain subsidiaries. To ascertain the
amount realized, we must decide the fair market value of
preferred stock and common stock warrants petitioners received as
part of the consideration for the sale of that stock.
FINDINGS OF FACT
Some of the facts have been stipulated for trial pursuant to
Rule 91 and are incorporated herein by reference. We find as
facts the parties' stipulations of fact.
During the years in issue, petitioners were members of an
affiliated group of corporations whose common parent was Hospital
Corporation of America (HCA), which was incorporated under the
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