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