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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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