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certain petitioners which disposed of some of their hospitals and
related medical facilities during taxable year ended 1987 are
required to include in income for that year the entire section
481(a) adjustment relating to a change in method of accounting
during 1987 that is attributable to those hospitals and related
medical facilities.
FINDINGS OF FACT
Some of the facts have been stipulated for trial pursuant to
Rule 91. The stipulated facts are incorporated herein by
reference and are found accordingly.
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
with the Director of the Internal Revenue Service Center at
1 (...continued)
and specifically involves taxable year ended 1987, which year was
not involved in the prior Memorandum Opinion. Other issues will
be addressed in one or more separate opinions subsequently to be
released.
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 Corporation.
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