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laws of the State of Tennessee.2 HCA maintained its principal
offices in Nashville, Tennessee, on the date the petitions were
filed. For each of the years involved in the instant case, HCA
and its domestic subsidiaries filed a consolidated Federal
corporate income tax return (consolidated return) on Form 1120
with the Director of the Internal Revenue Service Center at
Memphis, Tennessee.
Petitioners' primary business is the ownership, operation,
and management of hospitals. In Hospital Corp. of Am. v.
Commissioner, T.C. Memo. 1996-105, we set forth a detailed
description of petitioners' hospital operations, which will not
be reiterated here. We incorporate herein our findings of fact
contained in that Memorandum Opinion. In Hospital Corp. of Am.
v. Commissioner, 107 T.C. 73 (1996), issued September 12, 1996,
we addressed an accounting issue relating to the sale of the
stock involved in the instant opinion. Except to the extent they
apply to the instant opinion, we do not restate below the
findings of fact contained in that Opinion, but we incorporate
herein those findings of fact.
2 On Feb. 10, 1994, HCA was merged with and into Galen
Healthcare, Inc., a subsidiary of Columbia Healthcare Corp. of
Louisville, Kentucky, and the subsidiary changed its name to HCA-
Hospital Corp. of America. On that same date, the parent changed
its name to Columbia/HCA Healthcare Corp.
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