Hospital Corporation of America and Subsidiaries - Page 1

                                   107 T.C. No. 6                                     

                               UNITED STATES TAX COURT                                

                   COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket Nos. 10663-91, 13074-91     Filed September 12, 1996.           
          28588-91,  6351-92.                                                         

                    Ps own, operate, and manage hospitals and related                 
               businesses.  For taxable year ended 1987, pursuant to                  
               sec. 448, I.R.C., Ps not already using an overall                      
               accrual method changed their method of accounting to                   
               that method.  Also during 1987, HCAII, a wholly owned                  
               subsidiary of HCA, sold all of the stock of some                       
               subsidiaries that owned and operated hospitals and                     
               other facilities.  On audit, R determined that for                     
               certain of those subsidiaries (Category B Corporations)                
               Ps had to include in income for taxable year ended 1987                
               the entire sec. 481, I.R.C., adjustment relating to the                
               change in method of accounting required by sec. 448,                   
               I.R.C.  Ps contend that, even though the Category B                    
               Corporations were sold during 1987, pursuant to sec.                   
               448(d)(7)(C)(ii), I.R.C., HCA is entitled to include                   
               ratably in income over a 10-year period the portion of                 
               the sec. 481(a), I.R.C., adjustment attributable to the                

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

Last modified: May 25, 2011