- 4 -
1987 294,571,908.00
1988 25,317,840.00
Respondent also determined that the provision for increased
interest pursuant to section 6621(c) applied. 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 what
amount, if any, petitioners may exclude from income for taxable
years ended 1987 and 1988 pursuant to the nonaccrual-experience
method.
FINDINGS OF FACT
Some of the facts have been stipulated for trial pursuant to
Rule 91. We incorporate those stipulated facts herein by
reference and find them as facts herein.
During the years in issue, petitioners were members of an
affiliated group of corporations whose common parent was Hospital
Corporation of America (HCA).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
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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