- 3 - 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...)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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