Hospital Corporation of America and Subsidiaries - Page 3

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          trial, briefing, and opinion and will hereinafter be referred to            
          as the instant case.  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                                 
                         1987           294,571,908.00                                
                         1988           25,317,840.00                                 
          Respondent also determined that the provision for increased                 
          interest under 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 for decision in the instant opinion1 is whether              

          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 an opinion issued Mar. 7,            
          1996, we addressed one of the tax accounting issues.  Hospital              
          Corp. of America v. Commissioner, T.C. Memo. 1996-105.  The                 
          instant opinion addresses another of the tax accounting issues              
                                                             (continued...)           




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