Hospital Corporation of America and Subsidiaries - Page 9

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          business and kept separate books and records.  Each New Parent              
          continued to own and operate other hospitals, office buildings,             
          or medical facilities and remained in the hospital business as a            
          subsidiary of HCA.                                                          
               For purposes of computing gain from the sale of the stock of           
          the Category A Corporations to HealthTrust, petitioners computed            
          HCAII's basis in that stock by taking into account each                     
          subsidiary's earnings and profits through the date of sale.  At             
          that time, the earnings and profits of each Category A                      
          Corporation included only one-tenth of the section 481(a)                   
          adjustment with respect to the change in method of accounting.              
          Petitioners anticipated that in HealthTrust's consolidated                  
          Federal corporate income tax returns for the succeeding 9 taxable           
          years following 1987 the Category A Corporations would include              
          ratably in income the balance of their section 481(a) adjustments           
          relating to the change in method of accounting.                             
               For purposes of determining gain from the sale of the stock            
          of the Category B Corporations to HealthTrust, petitioners                  
          determined HCAII's basis in that stock based upon the values of             
          the assets and liabilities transferred by the New Parents to the            
          Category B Corporations as reflected on financial statement                 
          balance sheets.  Those assets included the full face amount of              
          the accounts receivable of the Category B Corporations, and hence           
          the assets encompassed some accounts receivable not theretofore             
          included in the income of those Category B Corporations employing           




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