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Robert J. Shilliday, Jr., Vallie C. Brooks, and William B.
McCarthy, for respondent.
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.
TYE 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
1 The instant case involves several issues, some of which have
been settled. The issues remaining to be decided involve matters
that may be classified into four reasonably distinct categories,
which the parties have denominated the tax accounting issues, the
MACRS depreciation issue, the HealthTrust issue, and the captive
insurance or Parthenon Insurance Co. issues. Issues involved in
the first three categories were presented at a special trial
session, 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. In a Memorandum Opinion
issued Mar. 7, 1996, Hospital Corp. of America v. Commissioner,
T.C. Memo. 1996-105, and an Opinion issued Sept. 12, 1996,
Hospital Corp. of America v. Commissioner, 107 T.C. (1996),
we addressed two of the tax accounting issues. The instant
opinion addresses the last of the tax accounting issues and
specifically involves taxable years ended 1987 and 1988, which
were not involved in T.C. Memo. 1996-105 (but 1987 was involved
in Hospital Corp. of America v. Commissioner, 107 T.C.
(1996)). Other issues will be addressed in one or more separate
opinions subsequently to be released.
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