- 3 - 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.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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